Adam Craggs and Nicole Kostic (RPC) analyse the recent case of Premier Foods and the criteria required to recover VAT; and explore the circumstances in which HMRC is entitled to rely on the defence of unjust enrichment.
In this month’s briefing, Andrew Goldstone and Stuart Crippin (Mishcon de Reya) review the key developments in the private client arena, including setting aside a trust which had triggered unexpected tax charges; the availability of entrepreneurs’ relief on the disposal of an asset used in a business; the accelerated payment notices regime; Samarkand and HMRC guidance; and a case highlighting the investment nature of furnished holiday lets.
Karen Cooper and Mairi Granville-George (Osborne Clarke) examine the Mr A v HMRC decision on a payment made by a bank to an employee under a compromise agreement.
If the UK votes to leave the EU, what would be the impact on case law and legislation? Tim Eicke QC, a leading public and EU law advocate, considers some of the issues that might arise.
Etienne Wong (Tax Chambers, 15 Old Square) looks at what the advocate general’s opinion in Larentia + Minerva means for holding companies seeking to recover VAT on share acquisitions.
Steve Bousher (Joseph Hage Aaronson) reviews recent decisions on accelerated payment notices as a new counter avoidance power used by HMRC.
Mark Middleditch (Allen & Overy) reviews recent tax developments affecting the City, including UK FATCA rules in relation to holding and treasury companies; a FTT case on the assumption of debt on share sales; BEPS and the US proposals to combat treaty abuse; and the EU Commission’s action plan in relation to the new tax transparency package.
Tax Journal's recent coverage on the direction of UK tax policy - with views from business, leading tax experts, the Oxford University Centre for Business Taxation and the Institute for Fiscal Studies.
The Knowledge, Analysis and Intelligence (KAI) directorate is HMRC’s central analytical team, which provides analysis and research on all areas of the tax system to HMRC and HM Treasury. Mike Hawkins, deputy director of KAI’s Enforcement and Compliance team, answers Tax Journal’s questions on HMRC’s research agenda.