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CORPORATE TAXES


Carrie Rutland and Dawn Register (BDO) set out the most common reasons why claims can lead to an HMRC enquiry and they advise on how to reduce those risks.
An FFT decision on unallowable purpose and a Supreme Court ruling on an EU law challenge are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.
The Supreme Court decision in NCL Investments Ltd and the Court of Appeal decision in Skatteforvaltningen are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May). 
The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Revised draft guidance on large business notification of uncertain tax treatment and the Court of Appeal’s decision in Embiricos are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.
Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).
The consultation on hedging risks for future share transactions and the FTT decision in Hargreaves are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005. 
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