ANALYSIS

Cutting edge analysis on tax issues.

Zoe Andrews

Mike Lane

Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

Nigel Doran

While the Supreme Court judgment in Vermilion provides clarity on some of the questions raised by the deeming rule, it does not touch on questions raised by a number of other common scenarios, writes Nigel Doran (Macfarlanes).

Andrew Howard

Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.

Max Schofield

New reporting requirements for platform operators come into force from 1 January 2024, explains Max Schofield (Devereux Chambers).

Katie Oliver

Gary Barnett

This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers the Supreme Court decision in Target Group, the CJEU ruling on ‘free gift’ promotions, the potential use of split payments in the collection of VAT and the draft legislation intended to ensure stability on the interpretation of VAT and excise laws.

Ian Zeider

Emily Clark

Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in BlueCrest, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?

Alistair Godwin

In light of the Upper Tribunal’s recent decision which took a restrictive view of the substantial shareholding exemption rules, a change to the legislation is now required, writes Alistair Godwin (EY).

Jonathan Athow

Jonathan Athow, HMRC’s director general of customer strategy and tax design, explains why tax simplification matters to HMRC and what they are doing to help deliver it.

Alex Rigby

James Anderson

James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.