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ANALYSIS
Cutting edge analysis on tax issues.
‘Golden bricks’: when does construction really begin for VAT purposes?
Richard Dalton
Michael Ridsdale
Richard Dalton (BDO) and Michael Ridsdale (Wedlake Bell) challenge the
orthodox view that a dwelling is regarded as being constructed for VAT purposes
when it has reached ‘golden brick’.
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
Tax risk insurance claims explained
Julian Feiner
W&I and specific tax risk insurance has proliferated and tax claims are
emerging. Julian Feiner (DAC Beachcroft) explains the unique framework
for claims.
Divide and conquer: the partition demerger story
Colin Askew
,
Matt Cummings
,
Alisha Kouser
Untangling a business from a group (or single entity) in a tax neutral fashion
takes time and care. Colin Askew, Matt Cummings and Alisha Kouser
(Eversheds Sutherland) provide a case study considering the tax issues on a
partition demerger.
Revisiting the boilerplate withholding tax clause via 1962 (and beyond)
Ceinwen Rees
Serene Ho
Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate
clauses exist and why it’s important to check that they are included in
the contract.
The new Labour government: challenges and opportunities
David Gauke
Bezhan Salehy
David Gauke and Bezhan Salehy (Macfarlanes) share their Treasury insights on
the practical challenges facing the new administration.
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
Scale to sale: tax considerations when selling a UK business
Liz Hunter
,
Nicola Simmons
,
Moustapha Hammoud
Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya)
explain the personal, employment and corporate tax issues.
Private client review for July 2024
Edward Reed
Kazia Gagg
Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for
private clients under the new Labour government and comment on a number
of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.
The dirty dozen
James Quarmby
The 12 most annoying stereotypes about the world of tax, according to James Quarmby (Stephenson Harwood).
Go to page
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400
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
Read all
Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
Read all
The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget