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RESEARCH-AND-DEVELOPMENT
Introducing CenTax: a new tax research centre
Arun Advani
Andy Summers
Arun Advani and Andy Summers (CenTax) explain how engagement with tax professionals is key to CenTax’s mission, and they outline three principles that will guide its work.
Stage One Creative Services Ltd v HMRC
R&D claim succeeds before FTT.
Collins Construction Ltd v HMRC
FTT rejects HMRC’s interpretation of contracted out expenditure in R&D rules.
Other cases that caught our eye: 18 October 2024
SDLT MDR claim denied: Shine Business Ltd v HMRC [2024] UKFTT 894 (TC) (7 October) is another in the long line of cases on the now-abolished SDLT multiple dwelling relief. Like all such appeals the decision is highly fact dependent. The FTT,...
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Other cases that caught our eye: 26 July 2024
Carried interest base cost shift: In N Millican v HMRC [2024] UKFTT 618 (TC) (5 July), the FTT upheld the taxpayer’s appeal that his disposal of an interest in a company did not fall within the special regime in the TCGA 1992 which applies...
Planning for the merged R&D regime
Carrie Rutland
James Rolfe
Carrie Rutland and James Rolfe (BDO) highlight practical issues concerning
the introduction of the new scheme which takes effect from April.
2023: a parting glance in the rear view mirror for corporate tax practitioners
Gerald Montagu
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
New R&D scheme misses the point
Justine Dignam
The latest R&D reforms were said to simplify the tax regime and encourage
business investment. The reality though is more complexity, writes
Justine Dignam (Markel Tax).
PE funds and master holding companies: traps for the unwary
James Shorland
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
Private schools VAT challenge
HMRC’s whistleblower reward scheme: what we know so far
Morgan Lloyd Trustees Ltd v HMRC
St Patrick’s International College Ltd and others v HMRC
Urgent action could be required on non-dom ‘double remittances’