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ANALYSIS

Cutting edge analysis on tax issues.

HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.
The Upper Tribunal in Innovative Bites has provided welcome clarity on a contentious point of statutory construction, writes Max Schofield (Devereux Chambers).
Katie Oliver and Gary Barnett (Simmons & Simmons) examine this month’s key VAT developments.
Anthony Inglese CB talks to David Milne KC about life at the Tax Bar and beyond.
Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).
The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).
Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
Giles Salmond (Stewarts) assesses the likely impact of Advocate General Kokott’s opinion in the Dutch pension fund cases.
Is Labour’s diagnosis of the tax gap accurate and has the party misjudged its non-dom proposals, asks James Quarmby (Stephenson Harwood).
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