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LITIGATION
Discovery assessments: the Supreme Court’s decision in Tooth
Ian Robotham
Clara Boyd
Clara Boyd and Ian Robotham (Pinsent Masons) examine the unanimous decision that clarifies the law in relation to discovery assessments.
Hoey: contractor loans, PAYE credits and the TOAA code
Rory Mullan
Rory Mullan QC (Old Square Tax Chambers) examines the Upper Tribunal decision in
S Hoey v HMRC
which provides a degree of clarity on the tax consequences of contractor loan schemes.
Balhousie: VAT on sale and leaseback arrangements
Julia Lloyd
Will Scott
Julia Lloyd and Will Scott (Norton Rose Fulbright) examine the Supreme Court's decision and its wider implications.
Euromoney and the main purpose test: is the case law consistent?
William Watson
William Watson (Slaughter and May) examines the First-tier Tribunal’s
decision and its wider commercial implications.
Mehrban: staleness takes the biscuit
HMRC can’t wait forever to make a discovery assessment.
Wellcome Trust and the reverse charge
Etienne Wong
There are always corners hidden in the world of VAT that bear illumination,
writes Etienne Wong (Old Square Tax Chambers).
Danske Bank upholds ‘reverse Skandia’: is EU VAT grouping a poisoned chalice?
Mark Agnew
Philippe Gamito
Mark Agnew and Philippe Gamito (Baker McKenzie) examine the
continuing viability of VAT groups in the light of a recent CJEU decision.
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.
Contentious tax quarterly
Constantine Christofi
Adam Craggs
HMRC seems more amenable to alternative dispute resolution, whilst also pushing for greater formality in tax appeals, report Adam Craggs and Constantine Christofi (RPC).
Tartaruga: locating the risk for IPT purposes
Dominic Stuttaford
Dominic Stuttaford (Norton Rose Fulbright) examines a tribunal decision on how an establishment is identified under the insurance premium tax regime.
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50
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