ANALYSIS

Cutting edge analysis on tax issues.

Sarah Bond

The Court of Appeal judgment restores order, write Sarah Bond and Helen Buchanan (Freshfields Bruckhaus Deringer).

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Tim Sarson

The Advocate General’s opinion on the CFC Finco exemption state aid case, new US regulations and an update on Pillar Two are among the developments in this month’s review by Tim Sarson (KPMG).

Giles Salmond

Giles Salmond (Stewarts) assesses the likely impact of Advocate General Kokott’s opinion in the Dutch pension fund cases.

James Quarmby

Is Labour’s diagnosis of the tax gap accurate and has the party misjudged its non-dom proposals, asks James Quarmby (Stephenson Harwood).

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.

Melville Rodrigues

Naomi Lawton

Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy) provide an overview of the new regime that offers additional flexibility and plugs a gap in the UK’s existing fund range.

Bill Dodwell

In light of reports that the Culture Secretary is lobbying for a reform of Gift Aid, Bill Dodwell (former OTS Tax Director) considers how the operation of that relief could be improved.

Sam Epstein

Edward Reed

Recent decisions on mixed use SDLT, taxpayer behaviour and the meaning of ‘service’ under the remittance basis rules are reviewed by Edward Reed and Sam Epstein (Macfarlanes).