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IPT
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Home
Corporation tax
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Corporation tax
CORPORATION TAX
R&D Disclosure Service: the best route to resolution?
Jon Claypole
Jack Sloggett
Jon Claypole and Jack Sloggett (BDO) welcome HMRC’s new R&D
Disclosure Service but explain it is not suitable in all circumstances.
Tax grouping (part 1): group relief and tax groupings
Maddy Potthast
Gavin Little
In the first in a series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) focus on the conditions for corporation tax loss
relief via group relief.
The smoke and mirrors of tax avoidance
Tom Wallace
It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.
The first year allowance (or full expensing)
Andrew Green
Lawrence Wild
Andrew Green and Lawrence Wild (FTI Consulting) discuss the latest
temporary investment incentives.
Preparing for corporation tax in the UAE: an in-house perspective
Raj Singh Bal
The new UAE corporate tax regime is an opportunity for heads of tax of affected groups to bring tax to the boardroom agenda. Raj Singh Bal (Aramex) sets out the key considerations.
Pillar Two and the GloBE rules
Naomi Lawton
James Burton
Ellen Birkemeyer
Mitchell Fraser
James Burton, Ellen Birkemeyer, Naomi Lawton and Mitchell Fraser (Allen & Overy) provide a 20 questions guide.
The corporation tax increase is approaching: rate changes from 1 April 2023
Ben Charles
Nigel Giles
Augmented profits, associated companies and interaction with QIPs are just some of the issues to consider in advance of the rate change from April, as Nigel Giles and Ben Charles (BDO) explain.
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).
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Reasonable to avoid s 455, but is it an unreasonable charge?
David Whiscombe
David Whiscombe (BKL) reviews the first GAAR Panel decision in favour of the taxpayer and argues that the underlying legislation is long overdue for repeal.
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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
HMRC manual changes: 28 February 2025
Government proposes further Finance Bill amendments, including to the temporary repatriation facility
Business rates relief for film studios
HMRC advisory fuel rates
Scottish landfill tax rates
CASES
Read all
The executors of L Elborne deceased and others v HMRC
Chelsea Cloisters Management Ltd v HMRC
HMRC v Asset House Piccadilly Ltd
Other cases that caught our eye: 28 February 2025
A Taxpayer v HMRC
IN BRIEF
Read all
Statutory residence: but why do you need to be here?
Ramsay reined in?
HMRC’s focus on PE firms’ VAT compliance
HMRC’s U-turn on limited partners
Salaried members update
MOST READ
Read all
A Taxpayer v HMRC
HMRC v Royal Bank of Canada
Finance Bill 2025 progress
Sonder Europe and serviced apartments: TOMS or no TOMS?
B Joseph v HMRC