ANALYSIS

Cutting edge analysis on tax issues.

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in BlackRock and Hargreaves Property, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.

Penny Simmons

Steven Porter

Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for large businesses on managing IR35 compliance risks.

Oliver Marre

Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.

Dan Williams

Adam Craggs

HMRC have formidable information gathering powers against which there are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at three common types of information notice and the extent to which they can be challenged.

Max Schofield

The Upper Tribunal in Innovative Bites has provided welcome clarity on a contentious point of statutory construction, writes Max Schofield (Devereux Chambers).

Katie Oliver

Gary Barnett

Katie Oliver and Gary Barnett (Simmons & Simmons) examine this month’s key VAT developments.

David Milne KC

Anthony Inglese

Anthony Inglese CB talks to David Milne KC about life at the Tax Bar and beyond.

David Pett

Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in Yes Minister-style obfuscation, writes David Pett (Temple Tax Chambers).

Helen Buchanan

Sarah Bond

The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

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