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TAX-PLANNING
Other cases that caught our eye: 25 October 2024
IHT implications under Forfeiture Act: Under the Forfeiture Act 1982, a person who has unlawfully killed another person cannot benefit from that person’s estate. However, where in the opinion of the court the justice of the case requires...
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
Other cases that caught our eye: 30 August 2024
Offshore employment: Bilfinger Salamis UK Ltd v HMRC [2024] UKFTT 736 (TC) (16 August) concerns the so-called host employer rules which apply where the ‘personal services’ of individuals employed by a foreign employer are ‘made...
When tax goes wrong
Michael Thomas KC
The position should be calmly evaluated at an early stage in order to put an
appropriate strategy in place, writes Michael Thomas KC (Pump Court
Tax Chambers). Easy to say in theory, but not always so easy to execute in
practice...
Are trusts an appropriate vehicle to hold shares in a family business?
Hayden Bailey
Hayden Bailey (Boodle Hatfield) considers the use of trusts as part of an ownership strategy for family businesses to enable succession planning.
G Haworth and others v HMRC
Upper Tribunal finds FTT correctly tested place of effective management of trusts.
Incorporation relief and ESC D32: a myriad of uncertainty
Gordon W Buist
Gordon W Buist (EQ Accountants) explains how the publication of
Spotlight 63 on landlord tax planning schemes has exposed a fundamental
flaw with incorporation relief from CGT.
Wholly and exclusively: does a tax motive prevent deductibility?
Ross Birkbeck
Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).
A new era for the UK patent box
Andy Jacott
Sarah Lord
All companies claiming patent box relief are subject to the new nexus regime
from 1 July 2021. Sarah Lord and Andy Jacott (Deloitte) explain how it works.
Tax and technology: horizon scanning
Paul Aplin OBE
Former ICAEW president, Paul Aplin OBE, explores how technology is changing the way we work and the skills we need.
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
Reporting of offshore interest
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
CGT anti-forestalling measures
Pensions tax changes in the Budget
Collins Construction Ltd v HMRC
Syngenta Holdings Ltd v HMRC
National Farmers' Union calls for reversal of IHT reforms