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ANALYSIS
Cutting edge analysis on tax issues.
Go City: end of the road for ‘protective assessments’?
Bryn Reynolds
A recent FTT decision provides a startling level of insight into HMRC’s
decision making process, writes Bryn Reynolds (Pinsent Masons).
International review for September 2024
Tim Sarson
The Irish Apple state aid case and the US electoral candidates respective tax
policies are among the recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Corporation tax rate complexities for corporate LLP members
Emma Rawson
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Private client review for September 2024
Edward Reed
Damiano Sogaro
Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Tax and the City review for September 2024
Mike Lane
Zoe Andrews
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
Lycamobile: can phone bundles lead to VAT blunders?
Giles Salmond
Giles Salmond (Stewarts) examines an FTT decision covering a variety of
VAT issues, including the time of supply, the voucher rules and the use and
enjoyment provisions.
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403
EDITOR'S PICK
Freebies
David Whiscombe
1 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
2 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
3 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
4 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
5 /7
SDLT: gardens, grounds and grazing
Max Schofield
6 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
7 /7
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
NEWS
Read all
HMRC manual changes: 4 October 2024
Public opposition to IHT increases remains strong, according to poll
Apprenticeships reforms
Chancellor reflects on non-dom changes
Scottish government consults on new building safety levy
CASES
Read all
D Hill and another v HMRC
C Brzezicki v HMRC
Andrew Quay Hull LLP v HMRC
Other cases that caught our eye: 4 October 2024
Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC
IN BRIEF
Read all
Non-dom reforms: shaping the regime
Non-dom reforms: IHT aspects
EU Watch: new mandate, new tax priorities
More on the Supreme Court’s decision in PGMOL
A bad Apple ruling
MOST READ
Read all
HMRC manual changes: 4 October 2024
Andrew Quay Hull LLP v HMRC
EU Watch: new mandate, new tax priorities
More on the Supreme Court’s decision in PGMOL
Freebies