Tax Journal

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.

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Adam Marshall (Berthold Bauer VAT Consultants) assesses the FTT’s rejection of HMRC’s narrow reading of Item 5 – and considers the consequences for healthcare staffing models.

Catherine Hill (White & Case) questions whether the proposed tax adviser registration regime is a proportionate response to the Government’s aim of raising standards.

The Court of Appeal’s reasoning in Sintra Global misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).

Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.