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Home
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Issue 1629
Home
Issue
Issue 1629
Issue 1629
28 July, 2023
Analysis
Reviewing HMRC’s consultation on transfer pricing reform
International review for July 2023
HMRC v Part 26A: can you cram the Crown?
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
GE Financial, treaty residence, and the meaning of ‘business’
OECD pillar talk: Pillar Two looming; Pillar One a step closer
EU withholding tax: will things move FASTER?
How to handle R&D enquiries
In conversation with... Dan Neidle of Tax Policy Associates
In brief
Self’s assessment: Inheritance tax
Marano: ‘special circumstances’ in penalty cases
When does a payment constitute a distribution?
News
HMRC manual changes: 28 July 2023
Action required on venture capital schemes, says Treasury Committee
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CIOT responds to CIS proposals
NICs exemption for pension remedy payments
New guidance on tax refunds for negative earnings
HMRC takes control of IPT forms
Reminder of business/non-business test
UK adopts Pillar Two accounting changes
Luxembourg ratifies UK double tax convention
UK agrees social security convention with EEA
Brazil and San Marino tax agreements given effect
CIOT urges caution with trials on 'innovative' tax policy
HMRC consults on tax and occupational health
CIOT and ATT urge clear, comprehensive guidance on taxation for charities
HMRC brings in extra tax from investigations
Government responds to PAC tax compliance report
Agent Update Issue 110
Cases
M R Currell Ltd v HMRC
I Strachan v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
One minute with
One minute with... Jessica McLellan
Trackers
HMRC manual changes: 28 July 2023
EDITOR'S PICK
When tax goes wrong
Michael Thomas KC
1 /7
VAT on food: conflicting confections and deemed delicacies
Max Schofield
2 /7
Back to BlackRock: the Court of Appeal restores order
Sarah Bond
,
Helen Buchanan
3 /7
Labour’s tax plans: aiming at the wrong target?
James Quarmby
4 /7
The non-doms reforms: a practitioner view
Helen McGhee
5 /7
Mind the gap! Extension of the Transfer of Assets Abroad legislation post-Fisher
Emily Osborne
6 /7
What the Budget means for non-UK resident trusts
Edward Hayes
7 /7
When tax goes wrong
Michael Thomas KC
VAT on food: conflicting confections and deemed delicacies
Max Schofield
Back to BlackRock: the Court of Appeal restores order
Sarah Bond
,
Helen Buchanan
Labour’s tax plans: aiming at the wrong target?
James Quarmby
The non-doms reforms: a practitioner view
Helen McGhee
Mind the gap! Extension of the Transfer of Assets Abroad legislation post-Fisher
Emily Osborne
What the Budget means for non-UK resident trusts
Edward Hayes
NEWS
Read all
HMRC manual changes: 17 May 2024
Taxpayers let down by poor HMRC customer service, says NAO
New HMRC guidelines on football agent contracts
Voluntary office holders’ travel expenses
EU Council reaches agreement on FASTER Directive
CASES
Read all
Kwik-Fit Group Ltd and others v HMRC
Beech Developments (Manchester) Ltd and others v HMRC
G Graham t/a Skin Science v HMRC
Other cases that caught our eye: 17 May 2024
C Upham and others v HSBC UK Bank plc
IN BRIEF
Read all
Paddocks: horse sense?
A Kwik decision from the Court of Appeal
Notification of liability
Kwik-Fit on unallowable purpose
PAYE: IR35 ‘set-off’ rules
MOST READ
Read all
Labour’s tax plans: aiming at the wrong target?
Back to BlackRock: the Court of Appeal restores order
BlackRock Holdco 5 LLC v HMRC
When tax goes wrong
HMRC to engage on non-dom changes, while Labour considers investment incentive