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ANALYSIS

Cutting edge analysis on tax issues.

Karen Cooper and Mairi Granville-George (Osborne Clarke) analyse the result of the recent Rangers case on EBTs.
 
Claire Hooper (EY) summarises the main measures introduced in the Summer Finance Bill (now the Finance (No. 2) Act 2015), including the number of amendments to the Bill during the course of its progress through Parliament.
 
Andrew Goldstone and Sarah Albury (Mishcon de Reya) report on recent developments.
 

Shiv Mahalingham (Duff & Phelps) provides a round-up of news affecting the transfer pricing sphere.

Heather Corben and Adrian Brettell (King & Wood Mallesons) consider the legislative history of FA 1986 s 77, the practical problems caused by using the wider meaning of stock and the revised Stamp Office interpretation causing difficulties in obtaining the relief.
 
Financial Secretary to the Treasury, David Gauke, answers questions on tax competitiveness and tackling avoidance.
 
Ashley Greenbank (Macfarlanes) answers questions on the UK government consultation on changes to its rules on the deductibility of corporate interest and the likely introduction of a fixed ratio rule.
 
Mark Middleditch (Allen & Overy) reports the latest tax developments that matter, including a consultation on a fixed ratio rule; patent box reform; country by country reporting; and the special corporation tax rate applying to payments of restitution interest made by HMRC.
 

Rowena Clifton and James Llewellyn (The VAT Consultancy) consider the Copthorn Holdings decision, which raises important questions about HMRC’s approach to its published guidance and how it should be held to account.

Giles Salmond (Eversheds) reviews HMRC guidance on VAT recovery for fund management services for defined benefit pension schemes following the judgment in PPG Holdings.
 
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