ANALYSIS

Cutting edge analysis on tax issues.

Steve Wade

The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.

Tanja Velling

Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.

Kunal Nathwani

There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).

Dominic Stuttaford

Aiden Hepworth

Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.

Klara Kronbergs

Edward Reed

In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.

Gerald Montagu

Elmira Jazottes

Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.

David Wright

ATED is an unconventional and surprisingly complicated tax. David Wright (ATT) recaps the basics and looks at the available reliefs.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.

David Haworth

Rose Swaffield

Financial institution notices represent a greater power for HMRC, but this does not mean that tax managers’ hands are tied, write David Haworth and Rose Swaffield (Freshfields).