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ANALYSIS
Cutting edge analysis on tax issues.
UK property fund vehicles: a tax update
Camilla Spielman
From PAIFs to RIFS, via CoACSs, REITs and LTAFs. Camilla Spielman (Eversheds Sutherland) examines the changing tax landscape for UK-based property funds.
Much ado about non-doms: the new policy paper
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) examine what
we know now following this week’s policy paper.
A capital blow for deducting management expenses
Kyle O'Sullivan
The Supreme Court has delivered its judgment in
Centrica Overseas Holdings
.
Kyle O’Sullivan (BCLP) reviews the case and its implications.
10 questions on Uncertain Tax Treatment
Abigail McGregor
Steven Porter
Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT
regime after two years of operation.
The Court of Appeal favours form over function in GE Financial
Kyle Rainsford
In
GE Financial Investments
, the Upper Tribunal favoured the functional
interpretation while the Court of Appeal favoured the territorial, writes
Kyle Rainsford (Addleshaw Goddard).
Protecting and passing family wealth
Sam Inkersole
Family investment companies, discretionary trusts, growth shares, offshore
bonds... Sam Inkersole (BKL) considers what can be done within the current
rules to pass wealth to the next generation and ultimately shield it from IHT.
Partnerships and SP D12
Tanja Velling
Alex Sim
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
VAT on private school fees: 10 takeaways
Etienne Wong
Etienne Wong (Old Square Tax Chambers) provides a guide to the key points
from the Labour government’s introduction of VAT on private school fees.
Disapplication of the option to tax: issues for landlords and tenants
Anisha Polson
Paul Beausang
The VAT option to tax disapplication rules pose a conundrum for landlords
and tenants. Paul Beausang and Anisha Polson (Eversheds Sutherland)
consider what should be done.
‘Golden bricks’: when does construction really begin for VAT purposes?
Michael Ridsdale
Richard Dalton
Richard Dalton (BDO) and Michael Ridsdale (Wedlake Bell) challenge the
orthodox view that a dwelling is regarded as being constructed for VAT purposes
when it has reached ‘golden brick’.
Go to page
of
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