ANALYSIS

Cutting edge analysis on tax issues.

Carolyn Steppler Elena Dunn Alice Martin

Alice Martin, Elena Dunn and Carolyn Steppler (Charles Russell Speechlys) consider the UK tax and practical risks arising from offshore trust loans, including unexpected IHT exposure, settlor charges and the consequences of irrecoverable debts.

Tim Sarson

Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.

Ben Elliott

Louis Triggs

Ben Elliott and Louis Triggs (Pump Court Tax Chambers) set out the three conditions for invoking the Inco principle, the factors that determine its application in practice, and the role it may play as Brexit-era drafting and rapid legislative change generate more disputes.

Nick Thornton

Nick Thornton (Fried Frank) argues that HMRC’s proposed expansion of the UTT regime is the wrong answer to the wrong question, and should be withdrawn.

Andrew Hawley

Andrew Hawley (Crowe UK) weighs the trade-off in HMRC’s CT return reforms: fewer routine ‘what does this mean?’ enquiries on the one hand, more targeted scrutiny of complex and subjective positions on the other.

Jihao Zhang

Consultant Jihao Zhang works through eight scenarios for offshore trusts under the new long-term residence test, covering living and deceased settlors, the IHT tail, transitional protections and the £5m cap.

Amelia Roffey

Henry Bennett-Gough

Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).

Rebecca Seeley Harris

Rebecca Seeley Harris (Re Legal Consulting) examines the potential grounds on which HMRC could appeal the judgment.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Gideon Sanitt Bahar Eken Wai Wan

Gideon Sanitt, Wai Wan and Bahar Eken (Macfarlanes) explain why multinationals operating in the UK should expect a more demanding transfer pricing landscape.

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