ANALYSIS

Cutting edge analysis on tax issues.

Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) share their views on the current tax regime for UK resident non-domiciled individuals and what might happen under a Labour government.

Gordon W Buist

Gordon W Buist (EQ Accountants) explains how the publication of Spotlight 63 on landlord tax planning schemes has exposed a fundamental flaw with incorporation relief from CGT.

Paul Farey

Paul Farey (AECOM) considers the FTT’s ruling on the Acorn Venture case and yet another discussion around what constitutes expenditure on plant.

Gary Barnett

Joao Martinho

The decisions in TP, Bolt and Realreed and consultation responses on the VAT exemption for fund management and energy saving materials are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).

Dominic Mathon

Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs.

Deeksha Rathi

Edward Milliner

Deeksha Rathi and Edward Milliner (Slaughter and May) reflect on recently announced changes in an area faced with global instability, net zero goals and political change.

Tim Sarson

Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.

Paula Ruffell

Astrid Vroom

Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.

Heather Self

Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.

Sebastian Prichard Jones

Andrew Crozier

HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).

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