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IPT
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COMPLIANCE
20 questions on QAHCs
Naomi Lawton
James Burton
Sorsha Reilly
James Burton, Naomi Lawton & Sorsha Reilly (Allen & Overy) provide a practical Q&A on the workings of the new regime that is designed to offer significant benefits to attract a wide range of investors and holding structures.
Tax considerations for M&A deals: due diligence and structuring
John Holt
Callum Grant
John Holt and Callum Grant (PwC UK) summarise the UK tax aspects of M&A transactions with a particular focus on acquisitions of high growth tech businesses.
Uncertain tax treatment: highlights from HMRC’s final guidance
Kate Alexander
Nick Evans
Kate Alexander and Nick Evans (Baker McKenzie) review the newly published
Uncertain Tax Treatments by Large Businesses Manual.
The plastic packaging tax: how it works
Ugo Onwumelu
Charlotte Sallabank
Charlotte Sallabank and Ugo Onwumelu (Katten Muchin Rosenman) explain key features of the new tax and how it will apply to businesses.
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Does FATCA breach data protection? Jenny goes to court
Adam Rose
Filippo Noseda
Filippo Noseda and A
dam Rose (
Mishcon de Reya) discuss
the data protection repercussions of a system of automatic exchange of information in light of recent court decisions in the US and UK.
Consultation on the UK’s new mandatory disclosure rules
Veronica McMahon
Some of the definitions may have changed from DAC 6 to UK MDR, but the
concepts are broadly the same, writes Veronica McMahon (Osborne Clarke).
When is a defective HMRC notice invalid?
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.
Contentious tax quarterly
Constantine Christofi
Robert Waterson
Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Kate Alexander
Nick Evans
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
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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
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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
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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
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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
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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