ANALYSIS

Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).

Rebecca Seeley Harris (Re Legal Consulting) examines the potential grounds on which HMRC could appeal the judgment.

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Gideon Sanitt, Wai Wan and Bahar Eken (Macfarlanes) explain why multinationals operating in the UK should expect a more demanding transfer pricing landscape.

The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).

In this month’s review, Sophie Dworetzsky (Lombard Odier) considers recent developments affecting tax on trusts, privacy concerns surrounding proposed changes to the Register of Overseas Entities and some key tribunal decisions.

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).