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PRIVATE BUSINESS TAXES
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
A third route to exit: tax consequences of continuation fund transactions
May Smith
Emily Szasz
May Smith and Emily Szasz (Freshfields) examine some of the key
tax considerations that arise in relation to the transfer of assets into a
continuation fund.
Structuring following the new rules for IHT business and agricultural property reliefs
Michael Thomas KC
Diversifying ownership will become an increasingly important strategy in
light of the new restrictions to APR and BPR, writes Michael Thomas KC
(Pump Court Tax Chambers).
Ten questions on the Apple judgment
Dominic Robertson
Amaury de Galbert
Does the CJEU’s judgment in
Apple
signify a major shift in tax State aid
cases? Or is
Apple
likely to be a one-off? Amaury de Galbert and Dominic
Robertson (Slaughter and May) investigate.
The post-election (anti-avoidance) enforcement landscape
Ross Birkbeck
With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
VAT, private school fees and anti-forestalling provisions: how far is too far (back)?
Shanzé Shah
Etienne Wong
Etienne Wong and Shanzé Shah (Old Square Tax Chambers) discuss the extent to which anti-forestalling legislation might challenge prepayments that attempt to preserve the existing VAT treatment of private school fees.
Wealth tax possibilities
Philip Simpson KC
It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
Tax aside? Private investment fund side letters
Deepesh Upadhyay
Benjamin Shem-Tov
Ben Jones
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds
Sutherland) examine the increasing use of side fund letters in a private
investment funds context and the associated most favoured nations process.
Tax and the energy sector: what’s in store for 2024?
Deeksha Rathi
Edward Milliner
Deeksha Rathi and Edward Milliner (Slaughter and May) reflect on recently announced changes in an area faced with global instability, net zero goals and political change.
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114
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