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ANALYSIS
Cutting edge analysis on tax issues.
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
Oliver Twentyman
Many advisers appear to be adopting a contrived and narrow interpretation of
the word ‘preferential’ in an attempt to provide commercial protection to EIS
investors on a winding-up, warns Oliver Twentyman (Azets).
Capital allowances: uncertainty over design costs resolved by Court of Appeal
Paul Farey
Paul Farey (AECOM) assesses the impact of the Court of Appeal’s judgment
in
Gunfleet Sands
.
Challenging HMRC’s debt management actions: lessons from Local Fuel
Daniel Williams
Michelle Sloane
A recent High Court decision provides valuable guidance for taxpayers
seeking to challenge enforcement action taken by HMRC’s Debt Management
team, write Michelle Sloane and Daniel Williams (RPC).
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
International review for April 2025
Tim Sarson
Key policy developments in the US and an AG opinion on VAT on transfer
pricing are among the topics examined this month by Tim Sarson (KPMG).
HMRC’s revised R&D guidance: the end of a long and winding road?
James Dudbridge
HMRC’s updated guidance marks the end of a long and winding road for
R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).
Finance Act 2025: special report
Ros Martin
A detailed report of this year’s Finance Act.
FA 2025 review: VAT on private school fees: a lack of clarity
Etienne Wong
On its face, the new legislation imposing VAT on the provision of education by a private school seems straightforward well put-together, even. It takes little time to realise, however, that perhaps the Government should have taken a couple...
FA 2025 review: The loans to participators regime no more (re)paying your way
Hugh Gunson
With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The loans to participators rules in...
FA 2025 review: Double remittances
Peter Vaines
Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...
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417
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 25 April 2025
DST was always meant to be temporary, says Exchequer Secretary
HMRC change approach to CIR reporting
R&D relief: HMRC to update guidance on going concern rules and intra-group transfers
Pre-development costs consultation postponed
CASES
Read all
WTGIL Ltd v HMRC
Vaccine Research Limited Partnership and another v HMRC
George Mantides Ltd v HMRC
Refinitiv Ltd and others v HMRC
Other cases that caught our eye: 25 April 2025
IN BRIEF
Read all
A statutory residence test bear-trap
Protected income and offshore income gains
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: The new FIG regime: who are the real winners?
Loan Charge review: call for evidence