ANALYSIS

Cutting edge analysis on tax issues.

A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.

Dominic Robertson

Deepesh Upadhyay

Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson (Slaughter and May) examine one of the most important withholding tax cases in years.

David Pett

David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider what is in the best interests of the beneficiaries as a class, how the sale proceeds are to be distributed and the tax consequences of any sale.

Michael Ridsdale

Gemma Williams

Exceptions to the doctrine of precedent do exist but, as a recent case illustrates, they will be rarely applied in practice, write Michael Ridsdale and Gemma Williams (Wedlake Bell).

Klara Kronbergs

Edward Reed

Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases concerning entrepreneurs’ relief, PPR and SDLT.

Ben Symons

The taxation of private equity executives has become highly politically contentious as we head into the next election. An Opposition policy costing document released in February this year (bit.ly/4dol4do) shows that the Labour Party plans to tax the...

Rebecca Sheldon

Rebecca Sheldon (Old Square Tax Chambers) considers the proposals from the Conservative Party that give a broad indication as to how the new regime is intended to operate, and what might be expected if the Labour Party wins the General Election.

Ross Birkbeck

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.