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ANALYSIS

Cutting edge analysis on tax issues.

Simon Yeo and Billal Malik consider the judgment in St Matthews (West) Ltd and others v HMRC on the legality of retroactive legislation.

The European Commission has opened state aid investigations into the transfer pricing arrangements of Apple, Starbucks and Fiat. Jonathan Schwarz takes a look at the important points

Graeme Nuttall explains recent innovative measures to promote the John Lewis employee ownership model, especially as a business succession solution

Coming on the heels of Perrin, the decision in Ardmore deals with the meaning of UK source interest. Frixos Hatjantonas reviews

HMRC has strengthened its organisational approach to tax avoidance by creating a new Counter-Avoidance Directorate. We talk to David Richardson, its first director, about its operation

Helen Lethaby takes stock of the changes which have fundamentally changed the rules of engagement between the financial sector and HMRC over the past few years, looking in particular at the impact of the banking code of practice and the GAAR on the behaviour of taxpayers, HMRC and the courts

Geoffrey Tack and Bridget Winters examine the Birmingham Hippodrome Theatre Trust decision and the power of HMRC to set off taxes across multiple accounting periods

With the Queen’s Speech opening a new session of Parliament last week, Chris Sanger takes a look at the key tax points. Plus: talking points

With the surprising decision handed down recently in Corbett, James Austen examines the facts and asks what planning opportunities, if any, the First-tier Tribunal decision could afford to other taxpayers who might qualify for entrepreneurs’ relief.

Finance Bill 2014 included proposed legislation for social investment tax relief, a relief available to investors in social enterprises from 6 April 2014. Tim Smith and Richard Wilson take a look.

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