Tax Journal

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Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.
Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of the main parties – with additional comment from the IFS and Tax Policy Associates.
Following a recent case, we can probably expect HMRC to be less flexible on taxpayer requests for more time to comply with information notices, writes Matthew Greene (Stewarts).
A new Finance Act and several recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
HMRC are taking a tougher line on agents’ fees but on some issues they appear to have misunderstood what happens in practice, write David Lloyd and Pete Hackleton (Saffery).
Kwik-Fit, Hotel La Tour and the FTT decision in Osmond are among the latest developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
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