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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for June 2024
Zoe Andrews
Mike Lane
Kwik-Fit
,
Hotel La Tour
and the FTT decision in
Osmond
are among the latest developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
FASTER: a European Withholding Tax Directive
Reinhart Devisscher
Paul Radcliffe
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
Pillar Two: assessing the impact on the UK FTSE 100
Lavina Hassasing
Alistair Nichol
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
Back to basics: Sale of assets at under value
Sadiq Hashmi
Ben Handley
A back to basics guide, by Ben Handley and Sadiq Hashmi (BDO).
What is the UK tax treatment of Dubai (DIFC) Foundations?
Will Timbrell
Kyra Motley
There is no equivalent to a Foundation registered with the Dubai International
Finance Centre Registrar of Companies under English law. How then should
they be treated for UK tax purposes? Kyra Motley and Will Timbrell
(Boodle Hatfield) investigate.
The VAT review for June 2024
Jo Crookshank
Gary Barnett
Two recent CJEU decisions on the deemed supply rules concerning donated
goods and the VAT status of vouchers, as well as the Court of Appeal’s
decision in Hotel La Tour, are among the developments included in this
month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
The rules of deduction: Hotel La Tour
Etienne Wong
What has changed since
BLP
? Etienne Wong (Old Square Tax Chambers) reviews the recent Court of Appeal ruling on VAT deductibility for professional fees incurred on share sales.
New guidance on 1.5% stamp tax charge and s 138 clearances
Jack Jones
David Wilson
After an uneventful Budget and Tax Administration and Maintenance Day, and with little by way of legislative proposals (except for those advising non-doms), some of the most interesting tax developments of recent months have come in the form of...
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
Requirement to file CIS nil returns
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Tax agent registration and financial services
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker