ANALYSIS

Cutting edge analysis on tax issues.

Richard Doran and Julian Balson (EY) examine the First-tier Tribunal’s decision in Cider of Sweden.

There are a wide range of tax considerations for a UK resident limited partner, writes Katherine Bullock (Field Court Tax Chambers).

Tim Sarson

OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG).

Georgia Hicks

As we await two Court of Appeal decisions, Georgia Hicks (Devereux Chambers) considers what HMRC’s new approach on the ‘business on own account’ test could mean for taxpayers.

Mark Stapleton

Nicolas Kokkinos

The government’s initial conclusions from its recent response document leave Mark Stapleton and Nicolas Kokkinos (Dechert) doubtful as to whether the stated aim of the review – to make the UK an attractive location for asset managers – will be achieved.

David Wren Reinhart Devisscher Paul Radcliffe

Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.

Edward Reed

Ross Pizzuti-Davidson

Several recent case decisions in the private client arena, including the correct interpretation of the ‘place of effective management’ tie-breaker test, are examined by Edward Reed and Ross Pizzuti-Davidson (Macfarlanes).

Kate Alexander

Nick Evans

Kate Alexander and Nick Evans (Baker McKenzie) review the newly published Uncertain Tax Treatments by Large Businesses Manual.

Sarah Bond

Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.