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TAX POLICY ADMINISTRATION
Hughes: a triumph which masks a forensic disaster
Jonathan Fisher KC
Insights into HMRC’s practices in the investigation of an allegedly complex
tax fraud described in the court’s judgment makes for compelling reading, as
Jonathan Fisher KC (Red Lion Chambers) explains.
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Tax and the City review for September 2024
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
The path ahead for MTD: review or reflect?
Paul Aplin OBE
The new government should look at how MTD fits into plans for digitalisation of UK tax administration more generally and at the wider opportunities technology presents for taxpayers and HMRC, writes Paul Aplin OBE.
Estoppel in a tax context
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) explain how
estoppel has recently been used in tax cases by HMRC and also by taxpayers.
Case management before the tribunal
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) consider the various stages
involved in an appeal to the First-tier Tribunal and focus on the FTT’s case
management powers throughout the process.
Much ado about non-doms: the new policy paper
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what
we know now following this week’s policy paper.
Tax risk insurance claims explained
Julian Feiner
W&I and specific tax risk insurance has proliferated and tax claims are
emerging. Julian Feiner (DAC Beachcroft) explains the unique framework
for claims.
Revisiting the boilerplate withholding tax clause via 1962 (and beyond)
Ceinwen Rees
Serene Ho
Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate
clauses exist and why it’s important to check that they are included in
the contract.
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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