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IPT
VAT
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BEPS
CFCs
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Double tax relief
Foreign profits
Residence
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UK competitiveness
Withholding taxes
Private business taxes
OMBs
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Private client taxes
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Settlements
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Settlements
SETTLEMENTS
ScottishPower and the limits of von Glehn
Suzanne Hill
Rupert Shiers
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
L v HMRC
FTT holds discrimination settlement payment not taxable.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
School fee planning: back in the Spotlight
Gordon W Buist
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
Disguised remuneration: the new settlement opportunity
Tom Wallace
Thomas Wallace (WTT Consulting) explains what advisers need to do
to take advantage of the variety of tax treatments that are on offer.
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
Murphy: earnings as profits and settlement payments
Darren Oswick
Matthew Norris
Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
Practical aspects of HMRC’s retrospective change on VAT and contract terminations
Clara Boyd
On 2 September 2020, HMRC published Revenue & Customs Brief 12/2020 setting out a change in the VAT treatment of payments made in respect of contract terminations and contractual disputes. HMRC’s new general rule is that most such payments will be...
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
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EDITOR'S PICK
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
1 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
2 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
3 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
4 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
5 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
6 /7
2024: that was the year that was
Jemma Dick
7 /7
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
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
NEWS
Read all
HMRC manual changes: 21 February 2025
HMRC launch e-invoicing consultation
NICs relief in special tax sites: postcode requirement introduced
Company size thresholds apply for off-payroll working rules
Paying voluntary NICs when abroad
CASES
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
R (oao) Anglia Ruskin Students’ Union v HMRC
B Joseph v HMRC
Lloyds Asset Leasing Ltd v HMRC
IN BRIEF
Read all
Salaried members update
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
BlueCrest: the CA ruling on Condition B
MOST READ
Read all
Salaried members: HMRC reverses position on the TAAR and Condition C
Lloyds Asset Leasing Ltd v HMRC
Salaried members update
US ‘rejects very nature’ of UN tax talks
Mersey Docks: you’re my wonderwall