ANALYSIS

Cutting edge analysis on tax issues.

David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.

Hugh Gunson

Hugh Gunson (Charles Russell Speechlys) examines when it is possible to obtain privacy and/or anonymity orders in tax tribunal proceedings in light of a recent Upper Tribunal decision.

Meenakshi Iyer

Joel Kara

Meenakshi Iyer and Joel Kara (BDO) review the outcome of the consultation on reforms to the UK’s transfer pricing, permanent establishments and diverted profits tax rules.

Tim Sarson

Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.

Carrie Rutland

James Rolfe

Carrie Rutland and James Rolfe (BDO) highlight practical issues concerning the introduction of the new scheme which takes effect from April.

Jon Preshaw

Ben Proctor

Significant employment tax charges can arise in certain insolvency situations where there was never an intention for rewards to be provided in connection with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).

Deepesh Upadhyay Benjamin Shem-Tov Ben Jones

Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds Sutherland) examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations process.

Clare Wilson

Edward Reed

Tensions between transparency and privacy and some recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).

Mark Whitehouse

Miranda Edwards

Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.