ANALYSIS

Cutting edge analysis on tax issues.

Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.

Emma Rawson OBE

The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.

Damiano Sogaro

Edward Reed

Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.

Philippe Gamito

Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).

Malcolm Gammie CBE KC

The Supreme Court stands at the head of the UK’s judicial appeals system. Malcolm Gammie CBE KC (One Essex Court) examines when permission to appeal to the Supreme Court is likely to be granted, and considers how taxpayers and HMRC are faring in securing permission.

Thomas Chacko

In two recent cases, the tribunal approached the question of what was qualifying research in a way that supports taxpayers’ claims, if the right evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) examine recent case law and draft legislation, and they look ahead to how financial services will be taxed under the Labour government.

Giles Salmond

Giles Salmond (Stewarts) examines an FTT decision covering a variety of VAT issues, including the time of supply, the voucher rules and the use and enjoyment provisions.

Philip Baker KC

Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).

Paul Aplin OBE

The new government should look at how MTD fits into plans for digitalisation of UK tax administration more generally and at the wider opportunities technology presents for taxpayers and HMRC, writes Paul Aplin OBE.

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