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ANALYSIS

Cutting edge analysis on tax issues.

HMRC has proposed new measures to tackle offshore evasion, including a criminal offence for corporates and a strict liability offence for those who fail to declare offshore income and gains. Jason Collins and Fiona Fernie (Pinsent Mason) examine the detail. 

Pete Miller (The Miller Partnership) writes on the abolition of the tax deduction for the amortisation of corporate goodwill.
 
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City following the Summer Budget, including bank levy rates; changes in rules for loan relationships and derivative contracts; and double tax treaty arbitration at the G7 summit. 
 

The first Conservative Budget for 19 years sees ‘Osborne unbound’, writes Chris Sanger (global head of tax policy, EY) in Tax Journal. This was ‘a reforming Budget’ which sets out plans for a lower tax future ‘but boosts the exchequer’s coffers greatly in the short term’.

With the first Budget of the new parliament, George Osborne showed himself to be a skilled politician but not a tax reformer, David Smith writes.

Eloise Walker and Jeremy Webster (Pinsent Masons) consider the ambit and some key practical issues arising out of structuring a true sale securitisation.

Your guide to the tax measures.

Chris Sanger (EY) provides an overview of the Summer Budget.
 

Liesl Fichardt and Robert Sharpe (Clifford Chance) review recent actions taken by tax authorities in WHT claims in relation to dividend arbitrage and similar arrangements.

Charles Yorke (Allen & Overy) reviews the Supreme Court’s decision in Anson v HMRC and its wider impact on entity classification.

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