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CORPORATE TAXES


Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the current status of the TCGA 1992 s 137 main purpose test.
The move to permanent full expensing marks a change in UK corporate tax strategy, writes Jasmine Kaur, Head of Capital Allowances at HM Treasury.
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
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).
Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).
Helen Coward and Lewis Currie (Charles Russell Speechlys) consider the consequences of unlawful distributions by UK companies, including the tax pitfalls to avoid.
Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.
Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.
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