ANALYSIS

Cutting edge analysis on tax issues.

Gary Barnett

This month’s review by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers three cases ranging from the FTT to the CJEU.

Constantine Christofi

Adam Craggs

Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).

Nigel Giles

Michael Flaherty

Michael Flaherty and Nigel Giles (BDO) provide a refresher guide to these intricate and wide-ranging rules which can easily be overlooked when advising on migration tax planning for individuals.

Cristiana Bulbuc

Lee Ellis

The tribunal rejects HMRC's argument to refuse a claim for enhanced R&D relief on grounds that the expenditure was 'subsidised', as Cristiana Bulbuc and Lee Ellis (Stewarts) report.

Jason Collins

Jason Collins (DLA Piper) discusses the current state of play following COP26 and explains why heads of tax will need to monitor and influence changes to general tax law with climate goals in mind.

A detailed guide to the announcements.

Bezhan Salehy

Rhiannon Kinghall Were

There are plenty of measures that will interest tax enthusiasts, write Rhiannon Kinghall Were and Bezhan Salehy (Macfarlanes).

Matthew Mortimer

Kirsten Hunt

Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.

Dominic Stuttaford

Sofia Casselbrant

Dominic Stuttaford and Sofia Casselbrant (Norton Rose Fulbright) consider the FTT’s decision in Hargreaves and its implications for the UK withholding tax regime.