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CORPORATE TAXES
HMRC’s approach to purpose-based enquiries
Helen Buchanan
Sarah Bond
Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
The electricity generator levy: an introduction
Hiral Bhatt
Hiral Bhatt (Alvarez & Marsal) examines how the new levy will work and uncovers some uncertainties yet to be resolved.
Tax and the City review for April 2023
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
Terminating an acquisition mid-completion
Eloise Walker
As contract terminations proliferate in uncertain economic times, Eloise Walker (Pinsent Masons) looks at the tax issues arising from terminating an acquisition before it completes.
Tax and the City review for March 2023
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Earn-outs in M&A transactions: working hard for capital treatment?
Dominic Robertson
Tomás McGrath
Tomás McGrath and Dominic Robertson (Slaughter and May) discuss
pitfalls and practical tips when considering earn-outs in M&A transactions.
Global Britain? Trade, customs and tax in 2023
Caroline Barraclough
Amanda Tickel
James Caldecourt
James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.
How to handle unallowable purposes enquiries
Helen Buchanan
Sarah Bond
Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share
their experience of the approach HMRC is taking to unallowable purposes
enquiries, in particular under CTA 2009 s 441.
Tax and the City review for February 2023
Zoe Andrews
Mike Lane
It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).
Tax and the City review for January 2023
Zoe Andrews
Mike Lane
This month’s round-up, by Mike Lane and Zoe Andrews (Slaughter and May).
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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
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
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
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers