ANALYSIS

Cutting edge analysis on tax issues.

With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).

Shanzé Shah

Etienne Wong

Etienne Wong and Shanzé Shah (Old Square Tax Chambers) discuss the extent to which anti-forestalling legislation might challenge prepayments that attempt to preserve the existing VAT treatment of private school fees.

Philip Simpson KC

It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).

Michael Thomas KC

The position should be calmly evaluated at an early stage in order to put an appropriate strategy in place, writes Michael Thomas KC (Pump Court Tax Chambers). Easy to say in theory, but not always so easy to execute in practice...

Kyle Rainsford

The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).

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).

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