ANALYSIS

Cutting edge analysis on tax issues.

When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.

Tim Sarson

This month’s update illustrates how countries around the world are using tax levers to address fiscal challenges. Tim Sarson (KPMG) reports.

Rupert Shiers

Laura Hodgson

Following the Supreme Court’s decision, Rupert Shiers and Laura Hodgson (Hogan Lovells) consider whether any routes remain to improve VAT recovery on share sale costs.

Jane Mellor

HMRC’s latest guidance still leaves key questions unanswered, writes Jane Mellor, Head of Professional Standards at the CIOT and ATT.

Aparna Nathan

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Sophie Dworetzsky

Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).

Adam Craggs

Liam McKay

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Emily Osborne

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Kapisha Vyas

Réka Mező

AG Kokott calls for a principled approach to the VAT treatment of transfer pricing adjustments – and questions the legacy of Arcomet, write Kapisha Vyas and Réka Mező (Simmons & Simmons).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) reflect on the judgment in Watts on purposive construction, Ripe on intangible fixed assets, the new Pillar Two safe harbours, and HMRC’s new transfer pricing guidelines.

Go to page of 453