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TAX POLICY ADMINISTRATION
Helping vulnerable individuals: a guide for tax professionals
Dawn Register
Chris Holmes
How do you spot the signs, and what steps should you take? Chris Holmes and Dawn Register (BDO) provide a practical guide for tax advisers.
Transfer pricing: why returns are rarely risk-free
Phil Maggs
Phil Sneade
Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Tristan Thornton
Joseph Howard
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
Private client review for February 2025
Dominic Lawrance
Sophie Dworetzsky
Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).
Sonder Europe and serviced apartments: TOMS or no TOMS?
Damon Wright
Damon Wright (K3 Tax Advisory) questions the Upper Tribunal’s ruling on the VAT Tour Operators Margin Scheme.
If I could turn back time: encouragement for taxpayers seeking rectification
Arthur Wong
Ben Elliott
Ben Elliott and Arthur Wong (Pump Court Tax Chambers) explain why
there are grounds for optimism for taxpayers seeking to rely on rectification as
a potential means of resolving disputes with HMRC.
Mersey Docks: you’re my wonderwall
Yousuf Chughtai
Davinder Sahota
Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision
which shows how complex and large structures can be considered to function
as plant for capital allowances purposes, even where other premises-like
functions may exist.
Tax and the City review for February 2025
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent tax
developments that matter, including the ruling in ScottishPower and HMRC’s
draft guidance on the multinational top-up tax and domestic top-up tax.
Lifecycle of a transaction: structuring an acquisition
Gemma Grunewald
In the first of a new series on the lifecycle of a transaction – from acquisition
to operation and ultimate exit – Gemma Grunewald (DLA Piper) examines
some of the key considerations for a buyer when structuring an acquisition.
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way