ANALYSIS

Clarification rather than a fundamental expansion of relief?

A reform more than a decade overdue.

The temporary windfall levy makes way for a permanent, price-triggered successor.

Low value imports.

Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.

Check in, but can you check out? Oliver Walker and Ellie Marques (Weil, Gotshal & Manges) explain why companies considering moving to the UK need to think carefully about the UK tax ramifications.

Sophie Dworetzsky (Lombard Odier) consders the tax policy direction of a possible Burnham government, HMRC’s proposed reckless statements offence, distributions reform, trust registration changes, hold-over relief and BlueCrest.

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.

Andrew Howard and Omar Asfar (Ropes & Gray) examine the employment-related securities and valuation lessons from the tribunal’s decision, including the limits of third-party deal pricing and the high bar for protection offered by professional advice.

Adam Craggs and Liam McKay (RPC) review recent procedural decisions on strike out, costs for HMRC’s pre-appeal conduct and disclosure, drawing out the practical risks for tax litigants.