TAX POLICY ADMINISTRATION

Tim Sarson

This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.

Tamar Ruiz

Matthew Mortimer

The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.

Kelly Stricklin-Coutinho

New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.

Craig Kirkham-Wilson

Craig Kirkham-Wilson (Simmons & Simmons) examines Measuring Tax Gaps 2023 and predicts more enforcement activity in relation to large businesses.

Kathryn Hart

Edward Reed

Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.

Sam Wardleworth

Sam Wardleworth (Pinsent Masons) examines lessons from a number of tribunal decisions over the past five years.

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Upper Tribunal decisions in JTI Acquisitions and Hotel La Tour, and HMRC’s latest annual report.

Anastasia Nourescu

Matthew Greene

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).

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