ANALYSIS

Cutting edge analysis on tax issues.

Lyndon Firth

Swati Thapa

The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) considers recent developments affecting tax on trusts, privacy concerns surrounding proposed changes to the Register of Overseas Entities and some key tribunal decisions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

Dominic Stuttaford

Katharine Wadia

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.

Victoria Hine Leah Fisher Steven Porter

Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).

Julius Konstantin Berling

Liesl Fichardt

Liesl Fichardt and Julius Berling (Quinn Emanuel) assess the Upper Tribunal ruling in Lycamobile and its implications beyond telecoms.

Paul Farey

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Glyn Edwards

Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.

Nigel Watson

Claire Withers

Nigel Watson and Claire Withers (Burges Salmon) consider the extension of EMI option terms to 15 years and the practical implications for plan design, legacy options and compliance.

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