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ANALYSIS

Cutting edge analysis on tax issues.

Bilateral investment treaties, which protect and promote cross-border investments, are one of many areas of law which may be relevant for tax lawyers. Timothy Lyons QC and Kelly Stricklin-Coutinho (Thirty Nine Essex Street) explain why

Chris Morgan (KPMG) provides a round-up of recent developments, including: recent OECD discussion drafts from the BEPS project; discussions on the introduction of a GAAR into the EU Parent-Subsidiary Directive; the CJEU judgment on TCGA 1992 s 13; and updates from Germany and Chile.

George Bull (Baker Tilly) considers what to expect in the Autumn Statement – the final one before next year’s general election.

Peter Halford (PwC Legal) reviews the decision in Trigg v HMRC, where the FTT held that euro redenomination clauses did not deprive bonds of QCB status.

The past year has caused much uncertainty in terms of the tax tribunal’s approach to procedural errors, such as the late filing of appeals and non-compliance with procedural directions. Taxpayers should pay attention to directions and time limits to ensure that they are met, writes James Bullock (Pinsent Masons).

Insurance premium tax (IPT) has now been in operation in the UK for 20 years. Daniel Lyons and David Fownes (Deloitte) look back at the IPT story so far.

Martin Zetter (Macfarlanes) provides this month’s international transfer pricing news, with updates from Hungary, Russia, Slovak Republic and Morocco.

Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments in the private client arena: the public register of corporate ownership; the tax liability of a John Constable painting acquired by the nation; the outcome of a transferable IHT nil rate band charity appeal; and lessons from a main residence exemption claim.

Jonathan Bridges (KPMG) examines the key points of the recently announced UK/German proposal for preferential IP regimes

The OECD recently released its discussion draft on the reform of the permanent establishment (PE) rules. Richard Collier (PwC) examines the proposals

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