ANALYSIS

Cutting edge analysis on tax issues.

Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.

Angela Savin

Andrew James

Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.

Richard Liu

Simon Skinner

With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.

David Jamieson

David Jamieson (Baker McKenzie) reviews the Supreme Court’s ruling on when a supply takes place for VAT purposes, with practical lessons for intra-group invoicing and insights into how UK courts are engaging with CJEU case law post-Brexit.

Jo Crookshank

Gary Barnett

Jo Crookshank and Gary Barnett (Simmons & Simmons) provide this month’s round-up of the latest VAT developments, including two CJEU rulings.

Andrew Dixon OBE

Andrew Dixon OBE, founder of Fairer Share, makes the case for the introduction of a proportional property tax.

Kyle Rainsford

Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard) revisits the basic principles of interpreting tax treaties in the UK.

Tim Sarson

Tim Sarson (KPMG) reports the latest trends and developments from around the globe.

Giles Salmond

Guy Bud

Giles Salmond and Guy Bud (Stewarts) assess the impact of a recent CJEU ruling on the VAT treatment of intra-group transfer pricing adjustments and the limits of tax authority powers to challenge input tax recovery.