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ANALYSIS
Cutting edge analysis on tax issues.
Insuring M&A tax risks: practical considerations for buyers
Shayaan Zaraq Bari
Nicholas Gardner
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining
W&I insurance with other tools may help bridge any gaps in tax risk coverage
and maximise protection for buyers.
The VAT review for December 2024
Gary Barnett
In this month’s review, Gary Barnett (Simmons & Simmons) reviews the
agreement on ViDA, the consultation responses on CBAM in the UK and the
impact of an Upper Tribunal decision on supplies by public bodies.
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
Rebekka Sandwell
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
Sam Wardleworth
Steven Porter
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
New anti-avoidance legislation: the liquidation of LLPs
Gideon Sanitt
Victoria Braid
The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
Lessons on SDLT overpayment relief from BTR Core Fund JPUT
John Shallcross
John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.
Tax on the build-to-rent and student accommodation sectors
Jonathan Legg
Jonathan Legg (Mishcon de Reya) considers some of the latest issues – and some of the oldest – in the build-to-rent and purpose-built student sectors, focusing on SDLT and VAT.
International review for November 2024
Tim Sarson
The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).
The new Overseas Workday Relief regime: worse than before?
Steve Wade
The proposed reforms to Overseas Workday Relief could have greatly
simplified administration for taxpayers, agents and HMRC. Steve Wade (EY)
examines what’s actually been proposed.
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Tanja Velling (Slaughter and May) reviews a significant FTT decision in
which the taxpayers were denied interest deductions on a loan created in an
intra-group reorganisation under the unallowable purpose rule.
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 2 May 2025
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CIOT seeks clarification on double remittances
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
Vaccine Research Limited Partnership and another v HMRC
WTGIL Ltd v HMRC
DST was always meant to be temporary, says Exchequer Secretary
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up