ANALYSIS

Cutting edge analysis on tax issues.

Jon Preshaw

Craig Thomson (CSM Tax Consulting) and Jon Preshaw (Jon Preshaw Tax Ltd) examine a recent tribunal decision that provides useful guidance on HMRC information requests and closure notices in the context of DPT enquiries.

John Chaplin

Rob Woodward

John Chaplin and Rob Woodward (BDO) explain the main tax consequences associated with the use of umbrella company structures.

Simon Howley

When it comes to trusts, is it the trustees or the beneficiaries who are treated as the purchaser for SDLT purposes? Simon Howley (Bell Howley Perrotton) provides a refresher guide.

Tim Sarson

Progress on BEPS 2.0, the EU’s public CBCR directive and plans for a new EU withholding tax system are among recent developments examined by Tim Sarson (KPMG).

Chris Nyland

Chris Nyland (Gowling WLG) examines four cases that encourage a more nuanced approach to sale and leaseback transactions.

Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) examine the First-tier Tribunal decision in Marlborough DP Ltd v HMRC that suggests the shortcomings in HMRC’s general approach following Rangers.

Marvin Reynolds

Jeffrey Webber

Marvin Reynolds and Jeffrey Webber (BDO) provide a practical guide to a relief for which claims are being actively challenged by HMRC.

Lisa de Silva

Edward Reed

Useful insights on discovery, potentially insolvent estates, the location of cryptoassets for tax purposes and HMRC’s use of nudge letters by Edward Reed and Lisa de Silva (Macfarlanes).