Kyle Rainsford (Addleshaw Goddard) examines the Upper Tribunal’s ruling that the UK-Isle of Man treaty permits UK taxation of an offshore developer’s property profits, despite the lack of a UK permanent establishment.
Jake Landman and Abigail McGregor (Pinsent Masons) examine what the Supreme Court’s AXA judgment means for the binding effect of group litigation rulings and the importance of defining common issues precisely.
In this month’s review, Joao Martinho and Gary Barnett (Simmons & Simmons) examine two decisions on transfers of going concerns and HMRC’s recent guidance on the VAT treatment of fund management services.
New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).
Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision.
The reclassification of OIGs may appear to be a narrow technical adjustment solely related to the operation of the temporary repatriation facility, but it has wider practical implications, as Liz Fothergill (Mercer & Hole) explains.