ANALYSIS

Cutting edge analysis on tax issues.

Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.

Clare Reeve Curatola

Kate Ison

Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.

Adam Craggs

Michelle Sloane

Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.

Fiona McRobert

Fiona McRobert, Assistant Director of HMRC’s ADR Team, explains how the department is ‘looking to embed a resolution mindset’.

Zoe Andrews

Mike Lane

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

Dominic Lawrance

Sophie Dworetzsky

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) share their views on the current tax regime for UK resident non-domiciled individuals and what might happen under a Labour government.

Gordon W Buist

Gordon W Buist (EQ Accountants) explains how the publication of Spotlight 63 on landlord tax planning schemes has exposed a fundamental flaw with incorporation relief from CGT.

Paul Farey

Paul Farey (AECOM) considers the FTT’s ruling on the Acorn Venture case and yet another discussion around what constitutes expenditure on plant.

Gary Barnett

Joao Martinho

The decisions in TP, Bolt and Realreed and consultation responses on the VAT exemption for fund management and energy saving materials are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).

Dominic Mathon

Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs.

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