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ANALYSIS

Cutting edge analysis on tax issues.

Some of the definitions may have changed from DAC 6 to UK MDR, but the concepts are broadly the same, writes Veronica McMahon (Osborne Clarke).
Unsure how the ‘double reasonableness’ test works? Sukhbir Binning and Ian Robotham (Pinsent Masons) provide a refresher guide to this ground-breaking legislation.
Phil Nicklin (CMS Cameron McKenna Nabarro Olswang) reviews the latest proposed changes to the REIT regime which are a significant improvement on the earlier draft measures.

Mark Bevington (ADE Tax) shares his view on the three key challenges taxpayers are currently facing and how their advisers should respond.

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005. 
Pete Miller (The Miller Partnership) examines a recent Upper Tribunal decision on a key test for business asset disposal relief.
Jeffrey Webber and Liam O’Doherty (BDO) examine the various options that are specifically aimed at preventing abuse of the existing rules. 
Card image Philip Greenfield Jonathan Hare Giorgia Maffini
Jonathan Hare, Giorgia Maffini and Phil Greenfield (PwC) examine the OECD’s model rules for pillar two. 
Omicron arrived in time to cloud the outlook for 2022, and rising inflation will be a problem for some months. But the outlook should then improve, as David Smith writes.
Expect a crypto crackdown and no more Mr Nice Guy at HMRC, write Gary Ashford and Morag Ofili (Harbottle & Lewis). 
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