ANALYSIS

Cutting edge analysis on tax issues.

Chris Morgan

Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including BEPS; Anson; information exchange on cross-border tax rulings; proposals for a CCCTB; and an EU and global summary.

Michael Avient

Heather Williams

Michael Avient and Heather Williams (UHY Hacker Young) review the recent decision in Degorce, one of a group of cases which will have a major impact on ‘trading’ structures.

Philip Harle

Rupert Shiers

Philip Harle and Rupert Shiers (Hogan Lovells) review the HMRC’s guidance on Anson and consider its impact and future ramifications.

Andrew Loan

Andrew Loan (Macfarlanes) reviews Prowting Trustees v Amos-Yeo concerning the rectification of a share transfer allowing a disposal to qualify for entrepreneurs’ relief, and considers the impact of inadvertent mistakes failing to achieve the desired tax result.

Victoria Howarth

Andrew Goldstone

In this month’s briefing, Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments in the private client arena, including the new non-dom proposals; changes to the IHT residence nil-rate band provisions; the end of offshore disclosure facilities; and views and behaviours in relation to ATED.

Charlotte Black

Robert Field

Charlotte Black and Robert Field (Farrer & Co) consider the VAT implications of charitable grants and analyse the key considerations concerning when they might become a taxable supply.

Dr Richard Collier

Philip Greenfield

Richard Collier and Philip Greenfield (PwC) review OECD's recommendations after publication this week of its final package of 13 reports constituting its base erosion and profit-shifting (BEPS) action plan.

With the release on Monday of the overwhelming bulk of the OECD’s final BEPS proposals, we are now close to the end of the policy development stage of what has always been an enormously ambitious project to reform the international tax rules. In...

Arabella Murphy

Claire Weeks

Arabella Murphy and Claire Roberts (Maurice Turnor Gardner) answer questions on the recent government consultation, looking at what is proposed, including the reform to non-UK resident trusts.

Mark Middleditch

Mark Middleditch (Allen & Overy) reports the latest tax developments that matter, including GAAP accounts and the concept of ‘fairly represents’; Julian Blackwell on CGT and enhancement expenditure; and HMRC’s response to Anson.