The position should be calmly evaluated at an early stage in order to put an appropriate strategy in place, writes Michael Thomas KC (Pump Court Tax Chambers). Easy to say in theory, but not always so easy to execute in practice...
The final CIS regulations and HMRC guidance don’t appear to measure up to
the original policy ambition of removing ‘the majority of landlord to tenant
payments from the scheme’, writes Kyle Rainsford (Travers Smith).
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
examines the Court of Appeal decisions in BlackRock and Hargreaves
Property, HMRC’s updated guidance on capital-raising arrangements and
share exchange clearances, and the OECD’s consolidated commentary on the
GloBE model rules.
Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.
HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.
The Upper Tribunal in Innovative Bites has provided welcome clarity on a contentious point of statutory construction, writes Max Schofield (Devereux Chambers).
Jim Harra’s responses to specific questions asked by the Treasury Select
Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).
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