ANALYSIS

Cutting edge analysis on tax issues.

Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).

Bryn Reynolds

Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.

Kara Heggs

Jisun Choi

Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.

Ray McCann

Unless shadow advisers are effectively regulated and HMRC can act closer to real time, we will soon once again be facing calls for regulation of the whole profession, writes Ray McCann.

David Whiscombe

HMRC may have overlooked their own statement of practice which says that such a transfer is in general a disposal, writes David Whiscombe.

Maddy Potthast

Gavin Little

In the first in a series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) focus on the conditions for corporation tax loss relief via group relief.

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.

John Endacott

John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.

Oliver Marre

The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).

Freddie Schwier

Dominic Foulkes

Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.

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