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COMPLIANCE
Party political tax proposals
Ami Jack
Ami Jack (Smith & Williamson) sets out a guide to the main political parties’
tax proposals in the run-up to the general election.
Retrospective law change on automated processes
Steven Porter
Catherine Robins
The government intends to change the law retrospectively to make it clear that HMRC can use automated processes to issue notices to file returns and to issue penalties, report Catherine Robins and Steven Porter (Pinsent Masons).
Locke: Court of Appeal again quashes follower and accelerated payment notices
Geoff Lloyd
Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
Self's assessment: will Labour make the tech giants pay their ‘fair share’?
Heather Self
In our continuing series, Heather Self examines the tax headlines in the national media. This week, the Labour party’s proposed tax raid on the tech companies.
Hybrid and other mismatches: exclusion amendments
Paul Freeman
The exclusion from the hybrid mismatch rules for regulatory capital instruments has been narrowed to comply with ATAD.
HMRC enquiries and data interrogation
Tony Monger
In every enquiry into a business, HMRC will seek to subject the accounting records to data interrogation. Tony Monger (Mazars) explains what HMRC is looking for.
Cliff edge: the meaning of ‘deliberate’
Constantine Christofi
Sam Brodsky
A recent tribunal decision erodes the behavioural distinction between ‘careless’ and ‘deliberate behaviour’, write Constantine Christofi (RPC) and Sam Brodsky (Gray’s Inn Tax Chambers).
The corporate criminal offences: two years on
Oliver Pumfrey
Most companies are simply not taking the necessary actions to ensure they have reasonable prevention procedures in place, writes Oliver Pumfrey (FTI Consulting).
Sch 23 bulk data-gathering powers: policing the gig economy
Matthew Greene
Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) discuss HMRC’s data-gathering powers that provide an effective tool to police the gig economy.
Corporation tax loss relief: CILR and the deductions allowance
Sarah Squires
Sarah Squires (Old Square Tax Chambers) reviews the operation of the loss restriction, the deductions allowance and the related compliance issues.
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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
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
Scottish aggregates tax on the horizon
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
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