ANALYSIS

Cutting edge analysis on tax issues.

HMRC are adopting a tougher stance with those who continue to deliberately mislead or refuse to cooperate, despite being in the COP 9/CDF process, writes Simon York CBE (Deloitte).

Edward Buxton David Haughey Sarah Bond

The Finance Bill rules introduce further complexity to the earlier draft provisions and place an unwelcome reliance on HMRC guidance, write Sarah Bond, Edward Buxton and David Haughey (Freshfields).

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Tim Sarson

This month, Tim Sarson (KPMG) reviews the Pillar Two Side-by-Side package, the Japanese tax proposals and the French Budget, and considers what to expect in the coming year.

Damon Wright

Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.

Alan Barr

Isobel d'Inverno

Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).

Finn Halton

Gregory Price

HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).

Sophie Dworetzsky

In this month’s update, Sophie Dworetzsky (Lombard Odier) reports the late change to the IHT reforms, the sharp increase in transparency and compliance obligations and some of the latest court rulings that matter.

Jivaan Bennett

Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.

Chris Barker

Matthew Emms

The Budget changes may have reduced the appeal of selling a company to an EOT but it remains a tax-efficient option, write Matthew Emms and Chris Barker (BDO).

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