ANALYSIS

Cutting edge analysis on tax issues.

As public CbCR regimes expand, AI tools could be used to reveal patterns in global tax data, writes Will Morris (PwC).

Ruby Hamid

The new fraud offence is a notable expansion of the failure to prevent (FTP) model creating corporate criminal liability. Ruby Hamid and Nicholas Gardner (Ashurst) examine actions for companies, and compare the rules with the existing FTP offences for bribery and tax evasion.

Sophie Dworetzsky

In this month’s report, Sophie Dworetzsky (Lombard Odier) reports growing concerns over draft tax reforms, and the latest court rulings on retrospective tax status and trustee replacement.

Paul McColgan Jason Groves Mark Saunderson

Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out some recommendations for UK professionals advising businesses with large US operations.

Harriet Betteridge

Which pensions will be taxed? Who is responsible for reporting and paying the tax? What’s the impact on planning? Harriet Betteridge (Charles Russell Speechlys) examines some key questions surrounding the proposed legislation.

Tamar Ruiz

Matthew Mortimer

Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent changes to the UK taxation of foreign exchange gains and losses.

Zoe Andrews

Mike Lane

The OECD’s ‘side-by-side’ system, the Prudential ruling and HMRC’s new technical note on the reserved investor fund regime are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Anthony Inglese

Paul Johnson

Paul Johnson, former Director of the Institute for Fiscal Studies, talks to Anthony Inglese CB about his career in economics and his views on UK fiscal policy.

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.

Angela Savin

Andrew James

Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.

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