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ANALYSIS

Cutting edge analysis on tax issues.

The latest changes to entrepreneurs’ relief do not suggest a clear pattern in HMRC’s views as to what is acceptable tax planning, writes Andrew Roycroft (Norton Rose Fulbright)

Helen Gilbey and Sarah Falk (Freshfields Bruckhaus Deringer) report

Derek Leith and Bob Cardno (EY) review the new support measures

Sandy Bhogal (Mayer Brown) highlights key features and potential issues

Nigel Doran (Macfarlanes) examines the new anti-avoidance rule

Leslie Allen and Waqar Shah (Mishcon de Reya) examine a recent decision on VAT treatment of contingent discounts and credit notes

Tarlochan Lall (Monckton Chambers) reviews the Upper Tribunal decision in Southern Cross, which illustrates that HMRC’s ability to recover a repayment of VAT is limited when the refund arises under a compromise agreement

Daniel Witt (International Tax and Investment Centre) and Dave Hartnett (consultant) highlight the work of the ITIC

Macklin v HMRC concerned where a pension plan was established for the purpose of double tax treaty relief. Jonathan Schwarz (Temple Tax Chambers) considers the case and its implications

Andrew Goldstone and Sarah Albury (Mishcon de Reya) review the latest developments that matter in the private client arena, including: HMRC’s hat trick of wins in cases against schemes promoted by NT Advisors; a consultation on VCTs; Lobler and rectification for the partial surrender of insurance policies; online filing of IHT accounts from August; and Tager and punitive tax-related penalties

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