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ANALYSIS

Cutting edge analysis on tax issues.

Avoiding avoidance premium
Card image Graham Webber
Graham Webber (WTT Consulting) explains why a more radical approach is needed to tackling unacceptable avoidance.
18 October 2024
EOTs: defending the indefensible or challenging the undefinable premium
Card image David Alcock
Card image Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain why these structures are increasingly under the spotlight.
16 October 2024
Brindleyplace Holdings: is s 75A (Hann)over now? premium
Card image Edward Hardy
Card image Helen Coward
Helen Coward and Edward Hardy (Simmons & Simmons) examine a recent FTT decision on SDLT, property investment partnerships and the anti-avoidance rule in s 75A.
16 October 2024
Home and away: how to go non-resident after McCabe premium
Card image Oliver Marre
The Upper Tribunal’s decision in McCabe shows how difficult it can be to challenge findings of fact when confronted with multi-factorial tests, writes Oliver Marre (5 Stone Buildings).
16 October 2024
Private client review for October 2024 premium
Card image Clare Wilson
Card image Edward Reed
Edward Reed and Clare Wilson (Macfarlanes) review the latest cases on EIS, BPR, reasonable excuse, and the principles of open justice and privacy.
16 October 2024
Is direct effect in VAT still alive in 2024? premium
Card image Fabian Barth
Fabian Barth (Alvarez & Marsal) challenges HMRC’s view that direct effect ceased to exist in VAT from 1 January 2024.
16 October 2024
Transfer pricing compliance: a guiding hand and a warning premium
Card image Simon Wood
HMRC are clearly not happy with the standard of analysis and documentation that they are currently seeing, writes Simon Wood (BDO).
10 October 2024
Why can’t we love HMRC like we love the NHS? premium
Card image Jonathan Riley
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
9 October 2024
Rebel without a causal link: HMRC’s position on proving carelessness premium
Card image Sophie Rhind
Card image Victoria Braid
Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
9 October 2024
At your disposal: conditionality under TCGA 1992 s 28 premium
Card image Rebekka Sandwell
Card image Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
9 October 2024
EDITOR'S PICKstar
NEWSRSS Read all
CASESRSS Read all
C Candy v HMRC
30 April 2025
G Quillan v HMRC
30 April 2025
WTGIL Ltd v HMRC
23 April 2025
IN BRIEFRSS Read all
MOST READ Read all
WTGIL Ltd v HMRC
23 April 2025
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