ANALYSIS

Cutting edge analysis on tax issues.

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Sophie Dworetzsky

Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).

Adam Craggs

Liam McKay

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Emily Osborne

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Kapisha Vyas

Réka Mező

AG Kokott calls for a principled approach to the VAT treatment of transfer pricing adjustments – and questions the legacy of Arcomet, write Kapisha Vyas and Réka Mező (Simmons & Simmons).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) reflect on the judgment in Watts on purposive construction, Ripe on intangible fixed assets, the new Pillar Two safe harbours, and HMRC’s new transfer pricing guidelines.

Iarlaith McCarthy-Hann

Rob Sharpe

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.

Jack Gifford

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Adam Marshall

Adam Marshall (Berthold Bauer VAT Consultants) assesses the FTT’s rejection of HMRC’s narrow reading of Item 5 – and considers the consequences for healthcare staffing models.

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