TAX POLICY ADMINISTRATION

Matthew Greene and Anastasia Nourescu (Stewarts) explain what the VAT Terminal Markets Order is, why it is useful and how the government plans to reform it.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.

Constantine Christofi

David Goldberg QC

Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).

Martin Shah

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

Abby Martin Lisa Rickelton Alex Lewis

HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.

Nuel Oji

Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

Brin Rajathurai James Burton Mitchell Fraser

Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.

Reinhart Devisscher Paul Radcliffe Ramzan Bashir

Current EU withholding tax procedures are costly, inefficient and prone to fraud. Is the Commission’s ‘FASTER’ proposal the answer? Paul Radcliffe, Reinhart Devisscher and Ramzan Bashir (EY) investigate.

Carrie Rutland

Helen Adams

Helen Adams and Carrie Rutland (BDO) provide a practical guide.

Ray McCann

Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.

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