ANALYSIS

Cutting edge analysis on tax issues.

Sam Wardleworth (Pinsent Masons) examines lessons from a number of tribunal decisions over the past five years.

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Upper Tribunal decisions in JTI Acquisitions and Hotel La Tour, and HMRC’s latest annual report.

Robert Waterson

Liam McKay

The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).

Anastasia Nourescu

Matthew Greene

Matthew Greene and Anastasia Nourescu (Stewarts) explain what the VAT Terminal Markets Order is, why it is useful and how the government plans to reform it.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.

Constantine Christofi

David Goldberg QC

Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).

Matthew Rowbotham

Many (although not all) of HMRC’s proposals on employee benefit trusts and employee ownership trusts will improve the tax rules, writes Matthew Rowbotham (Lewis Silkin).

Phil Nicklin

Phil Nicklin (EY) reviews the draft Finance Bill 2023/24 provisions on real estate investment trusts.

Craig Kirkham-Wilson

Gary Barnett

Legitimate expectation, directors’ fees, fixed establishments, reforming the TMO... Craig Kirkham-Wilson and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world.

Martin Shah

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

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