ANALYSIS

Cutting edge analysis on tax issues.

Gary Barnett

Mark Watterson and Gary Barnett (Simmons & Simmons) provide your monthly review of the VAT developments that matter.

What is the tax and accounting treatment of the repayment of a contributed surplus from a subsidiary company to a parent company and how should this be treated in the parent company’s books? Jackie Wheaton (BDO) considers the key points.

Brin Rajathurai

Murray Clayson

The OECD's programme of work subtly recasts the two pillars proposed in its earlier consultation, as Brin Rajathurai and Murray Clayson (Freshfields Bruckhaus Deringer) explain.

Steven Porter

Catherine Robins

Just how much hardship is required for the 'financial extremity' test? Steven Porter and Catherine Robins (Pinsent Masons) examine lessons from a recent Upper Tribunal decision.

Constantine Christofi

Adam Craggs

Adam Craggs and Constantine Christofi (RPC) consider the recent spate of IR35 cases that have been considered by the First-tier Tribunal, HMRC's increasing use of 'jeopardy amendments' and the increasing number of judicial review challenges being brought against HMRC.

Ian Hyde

Kevin Barrow

The Court of Appeal has recently interpreted the MSC legislation more widely than expected, paving the way for HMRC to target arrangements previously thought to be low risk, as Kevin Barrow and Ian Hyde (Osborne Clarke) explain.

Tim Sarson

Tm Sarson (KPMG) reviews the latest developments that matter.

Sarah Stenton

Lisa Vanderheide

While to some the arrival of the loan charge legislation feels like the beginning of the end of this saga, the reality may be that this is more like the end of the beginning, as Lisa Vanderheide and Sarah Stenton (Stewarts) explain.

David Walters

There is a strong case for simplifying the law on VAT on food, writes David Walters (Deloitte).

Gary Barnett

Zoë Arnautov

The recent decision in Warshaw and HMRC’s guidance on whether cumulative preference shares qualify as ‘ordinary share capital’ are at odds. Zoe Arnautov and Gary Barnett (Simmons & Simmons) explain the conflicting positions.

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