ANALYSIS

Cutting edge analysis on tax issues.

David Boneham (Deloitte) reviews a recent First-tier tribunal decision that uses FA 1996 s 84(1) – the ‘fairly represent’ loan relationship rule – as an anti-avoidance provision stopping accounting principles being used as a way of taking profits out of the tax net.

Andrew Goldstone

Jeffrey Lee

In this month’s briefing, Andrew Goldstone and Jeffrey Lee (Mischcon de Reya) review the key developments in the private client arena, including the recent decisions in Scott, Blackwell, Ames, Fountain and HCS Trustees.

Jeremy Goodwin

Jeremy Goodwin (Eversheds) answers questions on recent developments in pensions taxation following the Budget and considers the current HM Treasury consultation.

Amanda Brown

Amanda Brown (KPMG) examines Hilden Park and the scope of the abuse test following the Upper Tribunal’s judgment.

Sean McGinness

Rowena Clifton

Rowena Clifton and Sean McGinness (The VAT Consultancy) review the VAT rules on transfer of business assets for a going concern, including the position for connected parties and the impact of Intelligent Managed Services affecting VAT groups.

Heather Self

Heather Self (Pinsent Masons) reviews Lloyds Bank Leasing (No. 1) Ltd v HMRC, which examines whether the obtaining of capital allowances was one of the main objects of a transaction.

Gideon Sanitt

Gideon Sanitt (Macfarlanes) considers the rise in judicial review applications against HMRC, and the difficulty for taxpayers in holding HMRC to account.

Lee Squires

Fiona Bantock

Lee Squires and Fiona Bantock (Hogan Lovells) examine the recent decisions in Volkswagen Financial Services, Hilden Park and Redcats (Brands), and review recent HMRC briefs and consultations.

Mark Groom

As a number of HMRC and HM Treasury employment tax consultations are ending, Mark Groom (Deloitte) reviews the main points to emerge from the proposals so far.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter, including withholding tax consultation, regulatory capital, changes to DOTAS, and penalties for the GAAR.

Go to page of 454