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ANALYSIS

Cutting edge analysis on tax issues.

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005. 
Pete Miller (The Miller Partnership) examines a recent Upper Tribunal decision on a key test for business asset disposal relief.
Jeffrey Webber and Liam O’Doherty (BDO) examine the various options that are specifically aimed at preventing abuse of the existing rules. 
Card image Philip Greenfield Jonathan Hare Giorgia Maffini
Jonathan Hare, Giorgia Maffini and Phil Greenfield (PwC) examine the OECD’s model rules for pillar two. 
Omicron arrived in time to cloud the outlook for 2022, and rising inflation will be a problem for some months. But the outlook should then improve, as David Smith writes.
Expect a crypto crackdown and no more Mr Nice Guy at HMRC, write Gary Ashford and Morag Ofili (Harbottle & Lewis). 
Card image Kate Aitchison Chris Etherington Tom Dews
Chris Etherington, Tom Dews and Kate Aitchison (RSM) consider what the tax world may have in store for tax advisers in 2022.
Steve Edge (Slaughter and May) takes stock on the global corporate tax changes that have been grabbing press attention over the year.
Beware the clever procedural skirmish, warn Jason Collins and Lauren Redhead (DLA Piper).
With thoughts on virtual hearings from Hui Ling McCarthy QC (11 New Square Chambers).
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