ANALYSIS

Cutting edge analysis on tax issues.

Which pensions will be taxed? Who is responsible for reporting and paying the tax? What’s the impact on planning? Harriet Betteridge (Charles Russell Speechlys) examines some key questions surrounding the proposed legislation.

Tamar Ruiz

Matthew Mortimer

Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent changes to the UK taxation of foreign exchange gains and losses.

Zoe Andrews

Mike Lane

The OECD’s ‘side-by-side’ system, the Prudential ruling and HMRC’s new technical note on the reserved investor fund regime are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Anthony Inglese

Paul Johnson

Paul Johnson, former Director of the Institute for Fiscal Studies, talks to Anthony Inglese CB about his career in economics and his views on UK fiscal policy.

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.

Angela Savin

Andrew James

Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.

Richard Liu

Simon Skinner

With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.

David Jamieson

David Jamieson (Baker McKenzie) reviews the Supreme Court’s ruling on when a supply takes place for VAT purposes, with practical lessons for intra-group invoicing and insights into how UK courts are engaging with CJEU case law post-Brexit.