ANALYSIS

Cutting edge analysis on tax issues.

FA 2025 includes various provisions connected to the UKs implementation of the OECD Pillar Two global minimum tax initiative. There are three main things to note: Undertaxed Profits Rule (UTPR): The main mechanism by which countries will...

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) considers the consultations on advance tax certainty for major projects and on third party data.

Katie Oliver

Gary Barnett

Katie Oliver and Gary Barnett (Simmons & Simmons) review the latest decisions on VAT recovery and an AG opinion on the application of market value provisions in the VAT Directive.

Heather Self

Political pressure has resulted in HMRC adopting a slow and cautious decision-making process that remains to this day, writes Heather Self (Blick Rothenberg).

Arthur Wong

Ben Elliott

The recent cases of Bhaur and JTC illustrate the opportunities and challenges for taxpayers who have misunderstood the tax consequences of a transaction, write Ben Elliott and Arthur Wong (Pump Court Tax Chambers).

Jack Prytherch

Jack Prytherch (Osborne Clarke) explains how the new scheme will apparently take inspiration from US and Canadian whistleblower models.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review lessons from several important procedural decisions and a successful challenge to HMRC’s approach to subject access requests.