ANALYSIS

Cutting edge analysis on tax issues.

Nigel Watson

With speculation over the alignment of CGT and income tax rates, Claire Withers and Nigel Watson (Burges Salmon) ask what that would mean for employee equity and which policy choices it would leave unresolved.

Andrew Page

Andrew Page OBE (formerly HMRC) argues that the denial of relief for windfarm survey costs exposes a gap between the rules for capital allowances and intangible assets.

David Pett

David Pett (Temple Tax Chambers) writes that the FTT in CooperVision has ‘muddied the waters’ and made it more difficult to advise on whether shares are employment-related securities.

Matthew Mortimer

Elmira Jazottes

Matthew Mortimer and Elmira Jazottes (Mayer Brown) assess the impact of recent VAT decisions and changes to the UK tax net on the taxation of receivables finance structures.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including the latest GloBE package, Hunt on the limits of judicial correction, a timely reminder of the significant contribution made by the financial services, and the UTT implications of HMRC’s VAT guidance on fund management.

Dom Rothbarth

The options for taxing wealth are challenging. Dom Rothbarth (Boodle Hatfield) assesses the Chancellor’s options.

Kyle Rainsford

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.

Gary Richards

Gary Richards, Chair of the GAAR Advisory Panel, explains how the Panel makes its assessments and what advisers can learn from its published opinions.

Jake Landman

Abigail McGregor

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.

Gary Barnett

Joao Martinho

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.

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