ANALYSIS

Cutting edge analysis on tax issues.

Elyse Waller

Elyse Waller and Davinder Sahota (EY) review an Upper Tribunal ruling that provides insight on a term used in numerous places in the tax legislation, as well as demonstrating the importance of witness evidence.

Kyle Rainsford

Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of Blackrock HoldCo 5 to the international fiscal arena.

Clare Wilson

Edward Reed

Proposed changes to the CGT rules on transfers of property between separating spouses and a tribunal decision on information notices are among the developments reviewed by Edward Reed and Clare Wilson (Macfarlanes).

David Martin

We should grasp the opportunity to create a stable, coherent, simpler and fair tax system, argues David Martin (formerly Herbert Smith).

Matthew Greene

Frances Lewis

Matthew Greene and Frances Lewis (Osborne Clarke) examine HMRC’s victory before the tribunal in the K5K case.

Joshua Carey

Sam Way

The Court of Appeal’s decision brings refreshed simplicity to a tortured area of the law, write Joshua Carey and Sam Way (Devereux Chambers).

Matthew Mortimer

Kirsten Hunt

Matthew Mortimer and Kirsten Hunt (Mayer Brown) explain how the corporate interest restriction regime applies to UK acquisition finance transactions. Straightforward it is not.

Jonathan Hickman

Jonathan Hickman (BDO) takes a look at the possible tax proposals that were discussed by Liz Truss during her campaign trail.

Zoe Andrews

Mike Lane

The Upper Tribunal decisions in Altrad Services, BlackRock and Euromoney are examined by Mike Lane and Zoe Andrews (Slaughter and May).

Paul Aplin OBE

Given the current restrictions on participation in the pilot programme, the timescale for launching MTD for income tax is now very challenging, writes Paul Aplin OBE.

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