ANALYSIS

Cutting edge analysis on tax issues.

Constantine Christofi Craig Kirkham-Wilson Chris Sanger

New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).

Sara Sinfield

Beth Sercombe

Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision.

Liz Fothergill

The reclassification of OIGs may appear to be a narrow technical adjustment solely related to the operation of the temporary repatriation facility, but it has wider practical implications, as Liz Fothergill (Mercer & Hole) explains.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review recent decisions on unreasonable conduct, costs awards and protective costs orders, highlighting the practical lessons for taxpayers and advisers.

Jill Gatehouse Joe Williams Tom Gardner Emily Szasz

Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reflects on the run-up to the Budget and reviews developments on IHT on pensions, cryptoasset compliance and a recent case on corporate residence.

Adam Craggs

Tom Jenkins

Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions on treaty interpretation, deeming provisions and group litigation orders, alongside HMRC’s latest performance figures.

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