ANALYSIS

Cutting edge analysis on tax issues.

Dr Michael Taylor (PwC) considers whether Henderson LJ’s judgment in WTGIL could bring all sorts of intermediary services back within the scope of the VAT insurance exemption.

David Gordon

The discussion about tax responsibility should go beyond the rate of tax companies pay, writes David Gordon (100 Group Taxation Committee).

Matt Davies

Elizabeth Emerson

Matt Davies and Elizabeth Emerson (DLA Piper) consider core tax protections in share purchase agreements, and how they are impacted by tax warranty and indemnity insurance.

Erica Rees

Jenny Doak

Jenny Doak and Erica Rees (Weil, Gotshal & Manges) consider some of the practical considerations surrounding the proposed process for providing advance tax certainty for major projects.

Ritchie Tout

The recent changes to the Employee Ownership Trust rules bring the regime back to its intended purpose – and may impact many valuations, writes Ritchie Tout (Azets).

Alex Tostevin

Etienne Wong

The application of this VAT exemption remains both complex and uncertain, writes Alex Tostevin (Greenberg Traurig) and Etienne Wong (Old Square Tax Chambers).

Andrew Solomon

Andrew Solomon (Sullivan & Cromwell) explains why President Trump’s plans for ‘one big, beautiful Bill’ are heading for one big, ugly negotiation.

Benjamin Crompton

Sarah Bond

Sarah Bond and Benjamin Crompton (Freshfields) examine the draft legislation that amends certain aspects of the rules on transfer pricing and the diverted profits tax.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.