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ANALYSIS

Cutting edge analysis on tax issues.

Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
Liz Hunter and Graeme Whitfield (KPMG) examine the new registration requirements for EBTs and EOTs.
A new tax is designed to deter owners of energy supply businesses from removing assets on which the business’s survival depends, writes Colin Smith (PwC).
Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
HMRC’s revised guidance on early termination payments and several advocate general opinions are among the recent VAT developments reviewed by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Damien Crossley and Rhiannon Kinghall Were (Macfarlanes) examine the most complex of the conditions contained in the new regime.
Although some uncertainty remains, from 1 April there will be fewer situations where HMRC accepts that early termination and compensation payments are not subject to VAT, write Katie Raine and Richard Woolich (DLA Piper). 
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
Pillar one, UAE’s new federal corporate tax regime, and the Indian government’s Union Budget are among the recent developments examined by Tim Sarson (KPMG).
A growing number of taxpayers can expect to be involved in ‘early stage’ tax disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith) provide a practical guide for their advisers.
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