ANALYSIS

Cutting edge analysis on tax issues.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal’s purposive approach to the notional company fiction in Muller, HMRC’s consultation on extending the Uncertain Tax Treatment regime, and the proposed UK corporate re-domiciliation regime.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review recent decisions on costs for unreasonable behaviour, the use of AI in litigation and the scope of the FTT’s jurisdiction, as well as increased HMRC criminal investigations into advisers.

Karen Bannister

Gary Barnett

Karen Bannister and Gary Barnett (Simmons & Simmons) review recent decisions on VAT exemptions for securitisation vehicles and in-game currencies, the treatment of loyalty points, and the reduced rate for public EV charging.

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.

Chris Campbell

As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers.

Sir Sajid Javid

Anthony Inglese

Former Chancellor Sir Sajid Javid talks to Anthony Inglese CB about his journey from a childhood above the family shop to high office, and the realities of tax policy in government.

Tim Sarson

Once again, the US dominates the international tax news cycle, reports Tim Sarson (KPMG).

Nick Thornton

Is the UK’s domestic Permanent Establishment definition reform fair, simple and supportive of growth, or is it, in reality, yet further complexity, asks Nick Thornton (Fried Frank).

Vicky Topps

Karmjit Mader

HMRC’s increasing focus on upstream compliance and a more data-led, riskbased approach marks a clear shift away from the traditional enquiry cycle, as Vicky Topps and Karmjit Mader (KPMG) explain.