ANALYSIS

Cutting edge analysis on tax issues.

The disguised investment management fees (DIMF) rules were inserted as ITA 2007 ss 809EZA809EZH by FA 2015 and apply for years of assessment 2015/16 onwards. The declared purpose of the rules was to tax, as income, remuneration received by an...

Mike Lane

Zoe Andrews

Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...

Sarah Bond

Will Robinson

Sarah Bond and Will Robinson (Freshfields Bruckhaus Deringer) examine a (now final) Upper Tribunal decision on VAT recovery for loyalty schemes which endorses the Redrow approach.

Sean Randall

Sean Randall (Blick Rothenberg) examines a tribunal decision on the SDLT anti-avoidance in s 75A, which could have adverse consequences for cases where real estate is sold via corporate wrappers.

Richard Doran

Nicola Hine

Experts at KPMG examine an FTT decision concerning the income tax exemption and non-UK pension funds.

David Smith Economics expert

The budget deficit has been brought down to just over 1% of gross domestic product, a manageable level, and buoyant tax revenues can be credited with the improvement, as David Smith reports.

Richard Jeens

Rose Swaffield

The 2019 loan charge teaches us that there is more to statutory time limits than the technical analysis, write Richard Jeens and Rose Swaffield (Slaughter and May).

Gary Barnett

Martin Shah

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

Kunal Nathwani

Ben Jones

The international tax compliance landscape has become increasingly complicated and often unclear, as Ben Jones and Kunal Nathwani (Eversheds Sutherland) report.