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ANALYSIS

Cutting edge analysis on tax issues.

Tony Beare (Slaughter and May) describes the potential impact of two Upper Tribunal decisions in relation to the proportionality of VAT default surcharges.

With even more information at the Commission’s disposal from January next year, it seems inevitable that more fiscal state aid investigations are to come. Liesl Fichardt (Clifford Chance) looks at the Commission’s potential future targets.
 
Card image Peter Halford Stephen Morse Jonathan Hare

Jonathan Hare, Stephen Morse (PwC) and Peter Halford (PwC Legal) answer the key questions on the European Commission’s investigations into alleged illegal state aid as a way of tacking perceived corporate tax avoidance.

The EU’s ‘overreach’ on state aid has rankled the US tax authority, as Michael Lebovitz (White & Case) reports.

Adam Craggs and Robert Waterson (RPC) examine Sanderson, the latest discovery case in which the courts have attributed to the ‘hypothetical officer’ very little knowledge, notwithstanding extensive information having been made available to HMRC.

Michael Anderson and Katy Howard (Joseph Hage Aaronson) review the decision in Scotch Whisky, which provides helpful guidance on how a national court should apply the proportionality test in an EU law context.

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including the EC’s anti-avoidance package; challenges to the UK’s 45% tax rate on restitutional interest; and key tax developments from around the world.
 

Tim Smith and David Smith (Eversheds) report on the changes already due to take effect from April and look ahead to the likely changes in next month’s Budget.

Rupert Shiers (Hogan Lovells) comments on key areas where HMRC will focus in 2016 and where the law regulating HMRC and tax disputes will be developed.

Laura Charkin and Stephen Pevsner (King & Wood Mallesons) look back on a turbulent year for fund managers and consider the proposed new ‘income-based carried interest’ tax rules.

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