ANALYSIS

Cutting edge analysis on tax issues.

The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).

John Shallcross

John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.

Jonathan Legg

Jonathan Legg (Mishcon de Reya) considers some of the latest issues – and some of the oldest – in the build-to-rent and purpose-built student sectors, focusing on SDLT and VAT.

Tim Sarson

The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).

Steve Wade

The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.

Tanja Velling

Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.

Kunal Nathwani

There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).

Dominic Stuttaford

Aiden Hepworth

Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the practical impact of the Upper Tribunal’s decision in Gould.

Klara Kronbergs

Edward Reed

In this month’s review, Edward Reed and Klara Kronbergs (Macfarlanes) consider some of the more nuanced aspects of the non-dom reforms, as well as some key tribunal decisions affecting private clients.