ANALYSIS

Cutting edge analysis on tax issues.

Jon Preshaw

Ben Proctor

Significant employment tax charges can arise in certain insolvency situations where there was never an intention for rewards to be provided in connection with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).

Deepesh Upadhyay Benjamin Shem-Tov Ben Jones

Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds Sutherland) examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations process.

Clare Wilson

Edward Reed

Tensions between transparency and privacy and some recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).

Mark Whitehouse

Miranda Edwards

Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.

Matthew Greene

Guy Bud

HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).

Christopher Kientzler

Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.

Clare Reeve Curatola

Kate Ison

Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.

Adam Craggs

Michelle Sloane

Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.

Fiona McRobert

Fiona McRobert, Assistant Director of HMRC’s ADR Team, explains how the department is ‘looking to embed a resolution mindset’.

Zoe Andrews

Mike Lane

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).

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