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ANALYSIS

Cutting edge analysis on tax issues.

In the wake of updated UK CGT rules for non-residents, Nick Farmer and Stephen Hemmings assess the tax treatment for non-residents disposing of residential property in eight different jurisdictions

HMRC has issued revised guidance notes for taxing LLP members. George Bull and Malcolm Cook consider whether the taxman listened to the profession’s concerns

George Osborne will present his fifth Budget on 19 March in the context of an improving outlook for the economy. David Smith looks at what might be in store

Where loans are written off or provided for in the accounts of the lender, or released and written back in the accounts of the borrower, there can be exceptions to the basic rule on the tax treatment of loan relationships. Paul Howard explains

Wendy Walton and Miranda Chamberlain summarise recent happenings in the private client arena, including changes to the EU Fourth Anti-Money Laundering Directive and extra-statutory concession D33, the new HMRC helpline set up to assist flooding victims, and the business property relief decision in John Best

Chris Morgan reviews recent international tax developments, including updates from Canada, as well as the OECD’s BEPS project and common reporting standard, CJEU judgments on German exit taxes and the Hungarian ‘crisis tax’, and the M&S Supreme Court decision

After 11 years of litigation, the Supreme Court has held that a claimant can make successive claims for cross-border group relief as long as they are not time barred. Simon Whitehead and Rachel Garwood review the decision and examine the implications

Mark Baldwin considers the revised guidance on the new ‘salaried member’ rules, released last week by HMRC, that will treat members of an LLP as an employee for tax purposes in certain circumstances

Sara Luder reviews the proposed changes that will ease the rules restricting the availability of relief for corporation tax losses when companies change ownership

Martin Zetter examines developments in transfer pricing from across the globe, including the US, India and France

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