ANALYSIS

Cutting edge analysis on tax issues.

A recent High Court decision provides valuable guidance for taxpayers seeking to challenge enforcement action taken by HMRC’s Debt Management team, write Michelle Sloane and Daniel Williams (RPC).

Dominic Lawrance

Sophie Dworetzsky

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

Tim Sarson

Key policy developments in the US and an AG opinion on VAT on transfer pricing are among the topics examined this month by Tim Sarson (KPMG).

James Dudbridge

HMRC’s updated guidance marks the end of a long and winding road for R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).

Ros Martin

A detailed report of this year’s Finance Act.

Etienne Wong

On its face, the new legislation imposing VAT on the provision of education by a private school seems straightforward well put-together, even. It takes little time to realise, however, that perhaps the Government should have taken a couple...

Hugh Gunson

With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The loans to participators rules in...

Peter Vaines

Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...

Jo Bateson

The new Foreign Income and Gains (FIG) regime comes into effect from 6 April 2025 which has been overshadowed by all the discussion on the abolition of the non-dom regime. We should be spotlighting the FIG regime which is attractive for...

Ritchie Tout

FA 2025 Sch 6 introduces some fundamental and far-reaching changes to the Employee Ownership Trusts (EOT) tax rules. HMRC view the changes as pure anti-avoidance to provide them with the tools to counter the undoubted abuse of the EOT tax...

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