ANALYSIS

Cutting edge analysis on tax issues.

The options for taxing wealth are challenging. Dom Rothbarth (Boodle Hatfield) assesses the Chancellor’s options.

Kyle Rainsford (Addleshaw Goddard) examines the Upper Tribunal’s ruling that the UK-Isle of Man treaty permits UK taxation of an offshore developer’s property profits, despite the lack of a UK permanent establishment.

Gary Richards

Gary Richards, Chair of the GAAR Advisory Panel, explains how the Panel makes its assessments and what advisers can learn from its published opinions.

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) examine what the Supreme Court’s AXA judgment means for the binding effect of group litigation rulings and the importance of defining common issues precisely.

Gary Barnett

Joao Martinho

In this month’s review, Joao Martinho and Gary Barnett (Simmons & Simmons) examine two decisions on transfers of going concerns and HMRC’s recent guidance on the VAT treatment of fund management services.

Constantine Christofi Craig Kirkham-Wilson Chris Sanger

New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).

Sara Sinfield

Beth Sercombe

Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision.

Liz Fothergill

The reclassification of OIGs may appear to be a narrow technical adjustment solely related to the operation of the temporary repatriation facility, but it has wider practical implications, as Liz Fothergill (Mercer & Hole) explains.

Adam Craggs

Liam McKay

Adam Craggs and Liam McKay (RPC) review recent decisions on unreasonable conduct, costs awards and protective costs orders, highlighting the practical lessons for taxpayers and advisers.

Jill Gatehouse Joe Williams Tom Gardner Emily Szasz

Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.

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