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PARTNERSHIPS
Partnerships and SP D12
Tanja Velling
Alex Sim
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Taking an interest in partnerships: examining BCG v HMRC
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.
The taxation of SMEs in 2023
David Whiscombe
Disputes over partnerships, goodwill, distributions and VAT were among some of this year’s key points of interest for SMEs, writes David Whiscombe (BKL).
In conversation with... Rt Hon Lady Justice Falk
Anthony Inglese
Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
LLPs and intangibles: avoiding traps in M&A and intra-group transfers
Gregory Price
Lucy Urwin
Gregory Price and Lucy Urwin (Macfarlanes) discuss the challenges of dealing with LLPs in the context of M&A and group reorganisations in light of recent case law.
Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
Deciphering the leaseholder: beating HMRC’s odd habit
Chris Nyland
HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
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.
Significantly influential: the BlueCrest salaried members appeal
Oliver Marre
Amanda Hardy KC
The result of the
BlueCrest
appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
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EDITOR'S PICK
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
1 /7
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2 /7
2024: that was the year that was
Jemma Dick
3 /7
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
4 /7
The tractor tax
Stuart Maggs
5 /7
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
6 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
7 /7
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
2024: that was the year that was
Jemma Dick
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
The tractor tax
Stuart Maggs
A third route to exit: tax consequences of continuation fund transactions
May Smith
,
Emily Szasz
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
NEWS
Read all
President Trump’s ‘statement of intent’ rejecting Two-Pillar solution
HMRC manual changes: 24 January 2025
IHT proposals for pensions add ‘significant complexity’
Case for tax administration reform ‘overwhelming’, says CIOT
Up to £10bn VAT may have been underpaid by large businesses
CASES
Read all
HMRC v BlueCrest Capital Management (UK) LLP
ScottishPower (SPCL) Ltd and others v HMRC
HMRC v Sonder Europe Ltd
Global by Nature Ltd v HMRC
Other cases that caught our eye: 24 January 2025
IN BRIEF
Read all
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
A tale of two businesses
Pension ‘megafund’ reforms: how does tax fit in?
VAT on livestream events
MOST READ
Read all
The Mersey Docks and Harbour Company Ltd v HMRC
Global by Nature Ltd v HMRC
CIOT comments on non-doms provisions
HMRC v Yorkshire Agricultural Society
Tax exemption for LGBT Financial Recognition Scheme payments