ANALYSIS

Cutting edge analysis on tax issues.

Alex Ereira

Aron Joy

The carried interest reforms create substantial compliance burdens and may expose internationally mobile investment managers to double taxation, write Aron Joy and Alex Ereira (Weil, Gotshal & Manges).

Emma Rawson OBE

Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new Mandatory Tax Adviser Registration Manual.

Paul Townson

Chris Holmes

Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.

Tim Sarson

Pillar Two filing, an AG opinion on the EU anti-abuse rule and Budget measures in Australia and New Zealand are among the developments in this month’s review, by Tim Sarson (KPMG).

Fabian Barth

James Hurst

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.

Ray McCann

Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) considers the practical challenges created by bringing pensions within the IHT net, alongside developments in property taxation, trust transparency and internationally mobile wealth structures.

Jenny Batchelor

Ahmed Mobasshir

The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).

Ali Shokoohi

Jenny Tragner

Promising but flawed? Jenny Tragner and Ali Shokoohi (S&W) examine HMRC’s SME R&D assurance pilot, which offers earlier answers on difficult points but whose lengthy form-led design may create fresh uncertainty.

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