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TAX POLICY ADMINISTRATION
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Unless shadow advisers are effectively regulated and HMRC can act closer to
real time, we will soon once again be facing calls for regulation of the whole
profession, writes Ray McCann.
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
The sale of occupational income provisions following Grint
Oliver Marre
The
Grint
case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
Tax Administration Framework Review: dull sounding, but far reaching
Daniel Lusted
Daniel Lusted (BDO) examines what’s being proposed.
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
The contentious tax world in 2024
Adam Craggs
Liam McKay
This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.
In conversation with... Malcolm Gammie CBE KC
Anthony Inglese
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases. He talks to Anthony Inglese about life at the Tax Bar and beyond.
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
Rebekka Sandwell
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
Sam Wardleworth
Steven Porter
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
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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