Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
The definition of investment entities under FATCA, under the model IGA and under the UK IGA, regulations, guidance notes varies in important respects. Andrey Krahmal (Temple Tax Chambers) provides a summary of how the rules apply to investment entities most frequently encountered in practice.
Tax director of the OTS, John Whiting, lays out the Office’s achievements in simplification over the last five years. There is still, though, plenty of scope for further improvements, so how will it continue to make our tax system simpler?
As the OECD presses ahead with its agenda of expanding the PE concept, Richard Collier (PwC) asks how this will impact on existing structures and arrangements.
HMRC will be able to depart from its own guidance if it believes that tax avoidance might be involved, as the decision in Samarkand illustrates. Jeanette Zaman and Owen Williams (Slaughter and May) consider the uphill struggle that taxpayers could face to prove they have a substantive legitimate expectation.
Timothy Jarvis (Squire Patton Boggs) reviews lessons from the Upper Tribunal’s decision in Lobler on rectification and mistake
Faced with a variety of tax challenges, the chancellor needs to spell out a unifying theme in his forthcoming Budget, writes George Bull (Baker Tilly)
Shiv Mahalingham and Danny Beeton (Duff & Phelps) revisit the legislation, case law and HMRC practice relating to discovery assessments to discover what they will mean for taxpayers
HMRC is increasingly charging penalties to companies and senior accounting officers in respect of failures under SAO legislation. Lucy Sauvage and Ed Dwan (BDO) urge businesses to consider the impact on their reputation and their relationship with HMRC
Tax authorities are preparing for new models of international cooperation. Tessa Lorimer (Withers) outlines HMRC’s preparations to date, and the impact these reporting standards will have on its information gathering and enforcement powers