ANALYSIS

Cutting edge analysis on tax issues.

Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.

Sophie Rhind

It is encouraging to see the FTT dealing robustly with situations where HMRC fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Helen Adams

Helen Adams (BDO) offers some thoughts on the options and challenges posed by the potential reforms.

Anne Powell

Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.

Mark Whitehouse

Mairead Cummins

Tax Journal’s recent coverage of the Keighley case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.

Edward Reed

Emma Critchley

Edward Reed and Emma Critchley (Macfarlanes) recap the key private clients announcements in the Spring Budget, and they report some interesting procedural points when challenging HMRC enquiries.

Tim Sarson

Tim Sarson (KPMG) reviews the Biden Administration’s FY 2025 tax proposals and the OECD’s new guidance on Amount B of Pillar One.

Hayden Bailey

Hayden Bailey (Boodle Hatfield) considers the use of trusts as part of an ownership strategy for family businesses to enable succession planning.

Charles Havisham

Phil Roper

The thrust of HMRC’s guidance is to reject the notion that a profit split shouldn’t be used to reward risk control contributions, write Phil Roper and Charles Havisham (KPMG).

Go to page of 438