Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.
HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.
The Upper Tribunal in Innovative Bites has provided welcome clarity on a contentious point of statutory construction, writes Max Schofield (Devereux Chambers).
Jim Harra’s responses to specific questions asked by the Treasury Select
Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).
Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
.tmb-editorspic.jpg?sfvrsn=df04ab27_1)
