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Home
Corporation tax
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Corporation tax
CORPORATION TAX
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.
Ask an expert: NRCGT rebasing
Sarah Squires
Sarah Squires (
Old Square Tax Chambers) considers how the
rebasing rules apply to a recent non-resident's plans to sell
UK buy-to-let properties.
The super-deduction and SR allowance: claims on construction projects
Paul Farey
Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim.
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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
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HMRC manual changes: 22 November 2024
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
CASES
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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
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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
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Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania