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LITIGATION
The Court of Appeal’s guidance on IR35 employment status
Georgia Hicks
Georgia Hicks (Devereux Chambers) examines two cases which seek to give authoritative guidance on the application of the
Ready Mixed Concrete
and business on own account tests.
JTI Acquisition: the FTT casts a wide net on unallowable purpose
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a First-tier Tribunal decision that is important for anyone considering inter-group loan structuring.
A tale of two companies in two cities: the CJEU’s ruling on fixed establishment in Berlin Chemie
Karen Killington
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
NCL Investments: an 11-0 taxpayer victory
Angela Savin
Michael Brady
Angela Savin and Michael Brady (KPMG Law) review the impact of a recent
Supreme Court ruling.
VolkerRail: applying retained EU case law in pre-Brexit years
Richard Doran
Davinder Sahota
A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).
Contentious tax quarterly
Jason Collins
Lauren Redhead
Your quarterly review of developments in the contentious tax world, by
Jason Collins and Lauren Redhead (DLA Piper).
Capital allowances: what is plant?
Paul Farey
Paul Farey (AECOM) examines two recent decisions that raise some unique considerations and add to the discussion as to what can qualify for plant and machinery allowances.
Urenco: plant and machinery allowances
Will Scott
Susie Brain
Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
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.
Allam: a case full of interest
Lynnette Bober
Lynnette Bober (Gateley Legal) takes a closer look at a case involving
several diverse issues, not least the difficulties in overturning findings of fact
by the FTT.
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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
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
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers