ANALYSIS

Cutting edge analysis on tax issues.

Ceinwen Rees

The newly reformed tax on carried interest will subject carried interest to the payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland & Ellis) set out some of the key practical considerations.

Matthew Greene

Guy Bud

Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision which stresses the need for accountability and transparency from HMRC when issuing determinations.

Sophie Dworetzsky

This month’s update, by Sophie Dworetzsky (Charles Russell Speechlys).

Fabian Barth

Fabian Barth (Alvarez & Marsal) examines the distinction between when an assessment is ‘made’ and ‘notified’.

Richard Doran

John Hayton

Principled positions often adopted by HMRC can have the practical effect of avoiding or otherwise delaying judicial scrutiny of their decision-making process, write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).

Chris Sanger

At first glance, the Government’s revised approach to tax policy making retains much of the existing framework. There is, however, a significant change on the commitment to consultation, writes Chris Sanger (EY).

Andrew Solomon

Aharon Friedman

Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) report on an action-packed seven days in Washington.

Zoe Andrews

Mike Lane

Osmond, Eastern Power Networks and HMRC’s guidance on their new unilateral APA process are among the developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review some notable rulings on a range of procedural issues, as well as recent changes to the tribunal rules.

Rebecca Rose Bezhan Salehy Elvira Colomer Fatjo

Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes) take a practical look at UK interest withholding tax, highlighting common compliance pitfalls, HMRC’s approach and emerging complexities.

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