ANALYSIS

Cutting edge analysis on tax issues.

Emily Au

When implementing image rights contracts, employers must make concerted efforts to demonstrate the underlying commerciality of the arrangement by monitoring ongoing activities, write Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan).

Laura Hodgson

Laura Hodgson (Travers Smith) explains why the proposed new rules may require businesses to bolster the substance of their EU holding companies.

Sarah Gabbai

The government should take a more pragmatic approach to taxpayers affected by the loan charge, writes Sarah Gabbai (McDermott Will & Emery).

Lynnette Bober

Lynnette Bober (Gateley Legal) takes a closer look at a case involving several diverse issues, not least the difficulties in overturning findings of fact by the FTT.

Zoe Andrews

Mike Lane

Revised draft guidance on large business notification of uncertain tax treatment and the Court of Appeal’s decision in Embiricos are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

A Tolley report examines a recent decision of the immigration chamber of the Upper Tribunal, which has implications for tax hearings.

Catrin Harrison

Dominic Lawrance

Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine the Court of Appeal’s decision on partial closure notices in respect of domicile cases.

Mark Watterson

Gary Barnett

This month’s review by Mark Watterson and Gary Barnett (Simmons & Simmons) covers developments affecting the VAT land exemption, lease break fees and the recoverability of input tax when the VAT was never paid.