Tax Journal

Alison Lobb

Lisa Shipley

Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory foreign branch exemption means for UK businesses.

David Pett

The new loan charge settlement scheme may resolve many cases but offers limited benefits for higher-value cases, writes David Pett (Temple Tax Chambers).

Paul Minness

Alejandro Rivero

Paul Minness and Alejandro Rivero (RSM UK) assess the scope and practical implications of the new UK-to-UK transfer pricing exemption.

Jonathan Peacock KC

Peter Williams

HMRC say paid entry prize draws are standard rated, but the VAT exemption may not follow Gambling Act classification. Jonathan Peacock KC (11 New Square) and Peter Williams (RSM UK) explain.

Loviisa Langdon

Alexander Cox

Loviisa Langdon and Alexander Cox (Kirkland & Ellis) explain how the new carried interest rules apply to evergreen funds and highlight the complexities surrounding timing, valuation and average holding periods.

Rob Sharpe

Peter North

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, David Ward

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.

Evelyne Bagdassarian, José Ramón Vizcaíno, Gerald Montagu

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).