ANALYSIS

Political commentator Philip Stephens sets out the issues which will concern Philip Hammond as chancellor.

 

Sandy Bhogal (Mayer Brown) examines a recent tribunal case on whether certain insolvency procedures amount to a change of control for group relief purposes and looks at the potentially significant ramifications. 

 

BEPS Action 14 sets out the principles for resolving international tax disputes in the future. The International Chamber of Commerce will be contributing to this debate at an OECD level. Ian Hyde (Pinsent Masons) and Robert Thomas (chair of the UK tax committee of the International Chamber of Commerce) share the findings of a recent ICC UK survey, which reveals strong support for introducing a mandatory binding arbitration and for greater taxpayer involvement in the arbitration process.

 

Adam Craggs (RPC) reviews the decision in Mabbutt, which serves as an important reminder of the essential elements of a valid notice of enquiry into an individual’s specific tax return.

 

The UK reaches out, but is this the right time and in the right way? Steve Edge (Slaughter and May) examines the latest position on IP withholding tax.

 

Andrew Goldstone and Sarah Albury (Mishcon de Reya) review recent private client tax developments that matter, including the decisions in Miesegaes, Hall, Sparkasse Allgäu and King.

 

Lynne Rowland (Kingston Smith) explains the proposed changes to DOTAS hallmarks for inheritance tax.

 

Tom Wesel and Zoe Wyatt (Milestone International Tax Partners) review the revised EC’s Anti-Tax Avoidance Directive which will soon be adopted by the European Parliament to ensure a consistent and uniform implementation of BEPS recommendations across the EU.