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ANALYSIS

Cutting edge analysis on tax issues.

Allan Cinnamon (Cintax the Word Ltd) provides a quarterly update on tax treaty developments, including trends influenced by BEPS.

Before the election, many in business worried about Labour's economic policies. Under Jeremy Corbyn, they will have a lot more to worry about, David Smith writes. 
 
William Watson (Slaughter and May) considers whether the forthcoming regime TAAR for loan relationships will be less problematic than what currently exists. 
 
Lee Squires and Fiona Bantock (Hogan Lovells) review the VAT developments that matter, including: retrospective VAT grouping in Copthorn; abuse of rights in WebMindLicenses; vouchers used for business promotion in Associated Newspapers; and responses on the recent penalties consultation. 
 

Ian Stewart, the Director of Indirect Tax at HMRC, talks about his VAT teams’ work and how they are helping UK businesses.

Etienne Wong (Tax Chambers, 15 Old Square) considers what the Court of Appeal judgment in VWFS means for the hire-purchase sector and partial exemption generally.
 
Lord Carnwath’s ‘brief comment’ in Pendragon addresses the appellate jurisdiction of the Upper Tribunal and Court of Appeal in tax appeals. John Brinsmead-Stockham (Tax Chambers, 11 New Square) analyses its impact.
 
Chris Morgan (KPMG) provides your monthly round-up of tax developments in the international arena, including: Groupe Steria; management fees under UK treaty and minimum alternative tax in India; country by country reporting in Australia; debt capitalisation changes in New Zealand; and measures to encourage multinationals to locate headquarters in Thailand.
 
Finance Act 2015 introduced a new tax on diverted profits from 1 April 2015 that has potentially wide application to both UK and non-UK business with activities in the UK. Ben Jones and Cathryn Vanderspar (Eversheds) provide an overview of this new tax and examine key points.
 

Taxpayers who have incurred input VAT prior to VAT registration can claim this back. Or can they? Ruth Corkin (Grant Thornton) examines.

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