ANALYSIS

Cutting edge analysis on tax issues.

The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.

Thomas Chacko

In two recent cases, the tribunal approached the question of what was qualifying research in a way that supports taxpayers’ claims, if the right evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) examine recent case law and draft legislation, and they look ahead to how financial services will be taxed under the Labour government.

Giles Salmond

Giles Salmond (Stewarts) examines an FTT decision covering a variety of VAT issues, including the time of supply, the voucher rules and the use and enjoyment provisions.

Philip Baker KC

Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).

Paul Aplin OBE

The new government should look at how MTD fits into plans for digitalisation of UK tax administration more generally and at the wider opportunities technology presents for taxpayers and HMRC, writes Paul Aplin OBE.

Andrew Howard

Omar Asfar

Andrew Howard and Omar Asfar (Ropes & Gray) examine a case about whether an individual who is not a fund manager can be taxed under the carried interest rules.

Camilla Spielman

From PAIFs to RIFS, via CoACSs, REITs and LTAFs. Camilla Spielman (Eversheds Sutherland) examines the changing tax landscape for UK-based property funds.

Jo Crookshank

Gary Barnett

Jo Crookshank and Gary Barnett (Simmons & Simmons) examine the latest VAT decisions and the technical note on the extension of VAT to private school fees.