ANALYSIS

Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.

The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).

HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).

Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.

Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).

Anthony Inglese CB talks to practitioner Steve Edge about his career and the changing world of tax.

The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).

Gideon Sanitt and Sophie Rhind (Macfarlanes) review the decision in Cooke and its relevance for taxpayers of the FTT’s ability to consider rectification and rescission arguments.

The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).

In a sector reliant on software for tax solutions, Ben Lee (Andersen) explores the dangers of placing too much faith in ‘tax calculators’.