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Partnerships
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PARTNERSHIPS
Ask an expert: Guernsey limited partnerships - the transparency trap
Matthew Shayle
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
Mixed member partnerships rules: a complex knot to untangle
Liesl Fichardt
Emily Au
HMRC’s approach and recent tribunal decisions on mixed member partnership taxation have led to some uncertainty for individual and corporate partners. Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan) assess the current state of play and what can be done to minimise risks.
Back to basics: SDLT and partnerships
Anisha Polson
Paul Beausang
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
Odey and Hffx: partnerships with mixed membership
Hugh Gunson
Helen Coward
Guy Bud
Helen Coward, Guy Bud and Hugh Gunson (Charles Russell Speechlys) examine two decisions that raise interesting points of law relating to remuneration arrangements in partnerships with individual and corporate membership.
BlueCrest and partnership taxation: presents under the tree
Andrew Howard
Andrew Howard (Ropes & Gray) examines the decision that covers some
fundamental questions of UK partnership tax.
Indirect loans to participators
Natasha Kaye
Reshma David
Natasha Kaye and Reshma David (Cooley) examine the scope of the close
company indirect loan to participator rule in CTA 2010 s 459.
Tax and the City review for June 2020
Zoe Andrews
Mike Lane
Deeming rules, debits, partnerships and pension funds all feature within this month's update, by experts at Slaughter and May.
Partners and closure notices: making amends
Constantine Christofi
Adam Craggs
Adam Craggs and Constantine Christofi (RPC) examine the legislation and recent case law concerning closure notices in relation to partnerships.
Ingenious, but flawed
David Whiscombe
The importance of the basics.
CGT and non-resident partners
David Whiscombe
Partnerships are funny things, in many ways. None more so than for tax, and for CGT in particular.
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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
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania