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ANALYSIS

Cutting edge analysis on tax issues.

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).
Giles Salmond (Stewarts) assesses the likely impact of Advocate General Kokott’s opinion in the Dutch pension fund cases.
Is Labour’s diagnosis of the tax gap accurate and has the party misjudged its non-dom proposals, asks James Quarmby (Stephenson Harwood).
Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.
Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy) provide an overview of the new regime that offers additional flexibility and plugs a gap in the UK’s existing fund range.
In light of reports that the Culture Secretary is lobbying for a reform of Gift Aid, Bill Dodwell (former OTS Tax Director) considers how the operation of that relief could be improved.
Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).
Brin Rajathurai and Charles Yorke (Allen & Overy) explain how to navigate the complex and evolving landscape of tax and ESG.
Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).
David Jamieson (Baker McKenzie) provides an in-depth review of the Court of Appeal judgment in Prudential and assesses the potential  fees are invoiced and paid after changes in VAT group membership.
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