ANALYSIS

Cutting edge analysis on tax issues.

Sarah Bond

Sarah Bond and David Haughey (Freshfields) discuss some of the practical challenges which arise in tax disputes involving partnerships and their members.

Amelia Roffey

Helen Coward

Sweet relief? Helen Coward and Amelia Roffey (Simmons & Simmons) examine recent guidance from the Upper Tribunal on SDLT overpayment claims.

Heather Self

In the first of a new series of interviews with senior HMRC figures, HMRC’s Director for Intermediaries, Rob Jones, speaks to Heather Self about mandatory registration, adviser standards and what the department expects from the profession.

Lisa Shipley

Alison Lobb

Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory foreign branch exemption means for UK businesses.

David Pett

The new loan charge settlement scheme may resolve many cases but offers limited benefits for higher-value cases, writes David Pett (Temple Tax Chambers).

Alejandro Rivero

Paul Minness

Paul Minness and Alejandro Rivero (RSM UK) assess the scope and practical implications of the new UK-to-UK transfer pricing exemption.

Jonathan Peacock KC

Peter Williams

HMRC say paid entry prize draws are standard rated, but the VAT exemption may not follow Gambling Act classification. Jonathan Peacock KC (11 New Square) and Peter Williams (RSM UK) explain.

Peter North

Rob Sharpe

An obligation to correct tax return inaccuracies is coming. Rob Sharpe and Peter North (Cleary Gottlieb) examine the mechanics and some interpretative uncertainties.

David Ward Richard Miller Daniella Abel

Daniella Abel, Richard Miller and David Ward (Proskauer Rose) review HMRC’s consultation on treaty relief from withholding tax and assess the potential implications for various financing transactions.

Evelyne Bagdassarian Gerald Montagu José Ramón Vizcaíno

A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).

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