ANALYSIS

It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).

The new health and social care levy is a good case study in how necessary compromises and trade-offs result in a less coherent tax system, writes David Gauke (Macfarlanes).

Ian Zeider and Laura Hodgson (Travers Smith) provide a back to basics guide. 

The recent international agreement on the OECD’s two-pillar approach is intended to take unilateral digital tax measures off the table and put an end to these trade wars. But that does not necessarily mean there is no further role for trade law in this area, write Brin Rajathurai and Lorand Bartels (Freshfields Bruckhaus Deringer).

George Peretz QC (Monckton Chambers) considers the application of the Subsidy Control Bill to tax measures.

Ian Hyde and Matthew Greene (Osborne Clarke) explain the basics of legal professional privilege and consider related practical issues in a tax context.

Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.

Chris Holmes and Frances Edwards (BDO) summarise the existing basis period rules and examine how things will change under the new proposals.