Tax Journal

Jill Gatehouse, Emily Szasz, Joe Williams, Tom Gardner

Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.

Rob Sharpe

Peter North

Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reflects on the run-up to the Budget and reviews developments on IHT on pensions, cryptoasset compliance and a recent case on corporate residence.

Adam Craggs

Tom Jenkins

Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions on treaty interpretation, deeming provisions and group litigation orders, alongside HMRC’s latest performance figures.

Sarah Bond

David Haughey

Sarah Bond and David Haughey (Freshfields) discuss some of the practical challenges which arise in tax disputes involving partnerships and their members.