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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
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
1 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
2 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
3 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
4 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
5 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
6 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
7 /7
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
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
NEWS
Read all
Tax Journal authors for February 2025
Special report: The consultation on the impact on trusts of forthcoming reforms to BPR and APR
HMRC manual changes: 7 March 2025
HMRC consult on APR/BPR changes for trusts
Finance Bill passes Report Stage
CASES
Read all
HMRC v Appellants in the Post Prudential Closure Notice Group Litigation
C Poulton v HMRC
Advanced Hair Technology Ltd v HMRC
Other cases that caught our eye: 7 March 2025
The executors of L Elborne deceased and others v HMRC
IN BRIEF
Read all
The Good, the Bad and the Ugly: the IHT consultation on agricultural and business property
Home loan schemes: lessons from Elborne
New HMRC guidance on subcontracted and subsidised R&D
Finance Bill Report Stage amendments to the non-dom reforms
Statutory residence: but why do you need to be here?
MOST READ
Read all
HMRC advisory fuel rates
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Finance Bill Report Stage amendments to the non-dom reforms
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Ramsay reined in?