Tax Journal

HMRC’s latest guidance still leaves key questions unanswered, writes Jane Mellor, Head of Professional Standards at the CIOT and ATT.

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

AG Kokott calls for a principled approach to the VAT treatment of transfer pricing adjustments – and questions the legacy of Arcomet, write Kapisha Vyas and Réka Mező (Simmons & Simmons).

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) reflect on the judgment in Watts on purposive construction, Ripe on intangible fixed assets, the new Pillar Two safe harbours, and HMRC’s new transfer pricing guidelines.

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.