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ANALYSIS

Cutting edge analysis on tax issues.

Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open. 
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
Spending pledges are being flung around like confetti in the election campaign but politicians are coy about the fact that they will ultimately lead to higher taxes, as David Smith reports.
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
Paul Townson and Chris Holmes (BDO) consider some of the common corporate reorganisations and demergers that companies may undertake, and the key risks and issues with each type of transaction. 
Michael Thomas (Pump Court Tax Chambers) highlights some areas of topical interest for VAT and real estate.
The Court of Appeal's recent decision appears to set a high bar for establishing an unlawful breach of a taxpayer’s legitimate expectation, write Robert Waterson and Constantine Christofi (RPC).
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
Bryn Reynolds and Gary Barnett (Simmons & Simmons) provide your monthly review of the VAT developments that matter.
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