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ANALYSIS

Cutting edge analysis on tax issues.

The Upper Tribunal has now handed down the eagerly awaited judgment in HMRC v Murray Group Holdings and others, better known as ‘the Rangers case’. Robert Waterson and Adam Craggs review the lessons from the decision, which resulted in a loss for HMRC in its campaign against EBTs that it is likely to appeal.

Derek Leith identifies the salient points of the recent government consultation on the oil and gas fiscal regime

Ashita Gohil and Christopher Lallemand examine the recent Court of Appeal decision in Subway, regarding the VAT liability of the supply of ‘hot’ takeaway food

Andrew Goldstone and Victoria Howarth provide an update, including: the increased transparency of ownership of UK companies; new HMRC guidance on the taxation of damages; a recent decision on reasonable excuse for late returns; and why professionals acting as charity trustees need to be aware of potential conflicts of interest

Mark Middleditch takes over the reins of our popular monthly briefing on developments affecting the City. 

For any transaction involving bonds or notes, there are a number of potential difficulties that may arise, which may include issues involving stamp taxes, VAT, withholding tax, FATCA, and the tax treatment of the bond issuer and bondholders. Eloise Walker and Abigail McGregor provide a handy practice guide for advisers

Tori Magill reviews the changes to the contractual disclosure facility (CDF), and considers the impact for clients

Like all public bodies, HMRC must comply with the Freedom of Information Act 2000. Iain Macleod considers information provided in connection with the policy on accelerated payment notices

Peter Jenkins considers the development of a new threat to input tax recovery by partly exempt businesses receiving subsidies

Alternative dispute resolution (ADR) can be a cost-effective method of solving long running tax disputes. Dawn Register and Helen Adams provide your refresher guide on when ADR can help

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