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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for September 2024
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
Lycamobile: can phone bundles lead to VAT blunders?
Giles Salmond
Giles Salmond (Stewarts) examines an FTT decision covering a variety of
VAT issues, including the time of supply, the voucher rules and the use and
enjoyment provisions.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
The path ahead for MTD: review or reflect?
Paul Aplin OBE
The new government should look at how MTD fits into plans for digitalisation of UK tax administration more generally and at the wider opportunities technology presents for taxpayers and HMRC, writes Paul Aplin OBE.
Carried interest: Millican unCheyned
Andrew Howard
Omar Asfar
Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.
The VAT review for September 2024
Jo Crookshank
Gary Barnett
Jo Crookshank and Gary Barnett (Simmons & Simmons) examine the latest VAT decisions and the technical note on the extension of VAT to private school fees.
Estoppel in a tax context
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) explain how
estoppel has recently been used in tax cases by HMRC and also by taxpayers.
SDLT: gardens, grounds and grazing
Max Schofield
Max Schofield (Devereux Chambers) reviews recent case law on whether land
sold with the property is ‘non-residential’, rather than part of the grounds of
the house, for SDLT purposes.
Case management before the tribunal
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) consider the various stages
involved in an appeal to the First-tier Tribunal and focus on the FTT’s case
management powers throughout the process.
CCLA: AIFs can qualify for the SIF VAT exemption
Lauren Redhead
Clara Boyd
Clara Boyd and Lauren Redhead (DLA Piper) review the implications of the
FTT decision in
CCLA Investment Management Ltd
.
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417
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Tax Journal authors for April 2025
HMRC manual changes: 2 May 2025
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
Vaccine Research Limited Partnership and another v HMRC
WTGIL Ltd v HMRC
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
DST was always meant to be temporary, says Exchequer Secretary