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ANALYSIS
Cutting edge analysis on tax issues.
Transfer pricing compliance: a guiding hand and a warning
Simon Wood
Simon Wood (BDO) examines the new transfer pricing guidelines that are geared towards helping taxpayers understand HMRC’s expectations.
Why can’t we love HMRC like we love the NHS?
Jonathan Riley
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
Tax and the City review for October 2024
Mike Lane
Zoe Andrews
The latest developments that matter, reviewed by Mike Lane and
Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Autumn 2024
Adam Craggs
Harry Smith
There has been a steady rise in disputes concerning IHT and SDLT, report
Adam Craggs and Harry Smith (RPC).
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Georgia Hicks (Devereux Chambers) unpacks the Supreme Court decision,
considers the state of the employment status test, and gives guidance
for taxpayers.
The VAT review for October 2024
Jo Crookshank
Gary Barnett
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers cases concerning payments to acquire ‘credits’, VAT groups
and pension funds.
Officials advise, Ministers decide
Lord Macpherson
What Budget advice is the Chancellor likely to receive from the Permanent
Secretary at the Treasury? We asked former Permanent Secretary
Lord Macpherson for his thoughts.
How to handle tax on residential lease extensions
Chris Holmes
Martin Codd
Chris Holmes (BDO) and Martin Codd (Penningtons Manches Cooper)
consider a more cost-effective route for landlords when considering an
extension of a residential lease with their tenant.
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404
EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 11 October 2024
CGT needs serious reform, says IFS
HMRC Directions for the electronic submission of R&D notifications
Draft lifetime allowance regulations published
HMRC revise process for claiming employment expenses
CASES
Read all
HMRC v P Gould
Putney Power Ltd and another v HMRC
A Mudan and another v HMRC
Visual Investments International Ltd v HMRC
Other cases that caught our eye: 11 October 2024
IN BRIEF
Read all
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
Non-dom reforms: IHT aspects
EU Watch: new mandate, new tax priorities
MOST READ
Read all
Transfer pricing compliance: a guiding hand and a warning
HMRC manual changes: 11 October 2024
Case watch
Consultation tracker
Bed and breakfasting before the Budget?