An obligation to correct tax return inaccuracies is coming. Rob Sharpe and Peter North (Cleary Gottlieb) examine the mechanics and some interpretative uncertainties.
Daniella Abel, Richard Miller and David Ward (Proskauer Rose) review HMRC’s consultation on treaty relief from withholding tax and assess the potential implications for various financing transactions.
A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).
Jo Crookshank and Gary Barnett (Simmons & Simmons) review recent VAT developments concerning education, one-off sales, taxi services, the Capital Goods Scheme and online marketplaces.
When does preparation become trading? Hannah Manning and Elissavet Grout (Travers Smith) explore why the Upper Tribunal’s Putney Power decision matters for EIS, EMI, SSE and other tax reliefs.