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ANALYSIS

Cutting edge analysis on tax issues.

Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.

Peter Jenkins (Peter Jenkins Associates) examines the Capernwray case, in which the FTT decided that the construction of a community hall for a charity was not zero rated under the relevant residential and relevant charitable purpose tests.

Mark Middleditch (Allen & Overy) provides this month’s update, including: the limits of the purposive approach in tax avoidance cases; accelerated payments and DOTAS; draft changes on loan relationships and derivative contracts; notice clauses in tax indemnities; and the new HMRC Stamp Taxes on Shares Manual

Sara Luder (Slaughter and May) explains why politicians should think carefully about the consequences of proposed tax changes

This year’s Finance Act has made significant changes to the taxation of partnerships with a mix of individual and non-individual members. Howard Murray and Josh Lom (Herbert Smith Freehills) provide your guide to the new rules

The tax transparency agenda is now relevant to all sectors, and brings with it compliance burdens, risks and opportunities. Businesses need to consider how they address this challenge by developing a proactive approach to transparency and wider tax governance, writes Tim Law (Engaged Consulting Ltd)

Anthony and Tracy Hancock v HMRC illustrates the limits of both the Ramsay doctrine and the purposive construction of legislation. Pete Miller (The Miller Partnership) takes a look at the case

Andrew Roycroft (Norton Rose Fulbright) reviews the decision in the case of Bupa Insurance, which serves as a reminder that a tax avoidance purpose is, of itself, not sufficient for HMRC to deny a taxpayer its intended tax outcome

In this month’s briefing, Lee Squires and Fiona Bantock (Hogan Lovells) examine four recent VAT cases: Airtours, Vodafone, HSM Law and Emblaze Mobility Solutions

The forthcoming Scottish referendum will be fought on many issues but taxation, and in particular North Sea taxation, is one of the most important, as David Smith reports

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