Adam Craggs (RPC) takes a look at the First-tier Tribunal decision in Rotberg, and the extent of the tribunal’s jurisdiction
Rupert Shiers (Hogan Lovells) considers the Court of Appeal judgment in Lloyds TSB Equipment Leasing (No. 1) and HMRC’s new-found enthusiasm for applying main purpose tests.
While the Court of Appeal recently denied VAT recovery on costs associated with corporate restructuring and/or refinancing deals, it may be that the specific facts of BAA and Airtours mean the impact of these decisions can be contained. Judith Lesar and David Anderson (PwC Legal) examine both cases.
Andrew Goldstone and Victoria Howarth (Mishcon de Reya) review recent developments, including consultations on VCTs, social investment tax relief and income tax allowance restrictions for non-residents; changes to the tax treatment of commercial loans taken out by non-doms; ATED; and guidance on dual employment contracts
Chris Morgan (KPMG) summarises recent international tax news, including updates from India, China and Poland; the CJEU decision in the Nordea Bank Danmark A/S case in Denmark; and updates to the OECD Model Tax Convention
Martin Zetter (Macfarlanes) provides an update on the Amazon hearing in the US; plus transfer pricing news from India, Bolivia and Tanzania; and the OECD consultation on BEPS action 11
HMRC is consulting on the enactment of ESC D33. Paul Howard (Gabelle) reports.
Gary Barnett (Simmons & Simmons) says the Court of Appeal's decision in Airtours is a reminder of the difficulties that can arise in applying VAT to tripartite situations when determining the right to input VAT recovery.
Chris Davidson reviews the anti-avoidance measures in the current Finance Act and surveys the horizon for the next step in HMRC’s anti-avoidance journey.
HMRC’s position on the unallowable purpose rule seems as complex as ever. Mike Lane reviews where things currently stand