ANALYSIS

Cutting edge analysis on tax issues.

Sophie Rhind

Sophie Rhind and Victoria Braid (Macfarlanes) examine a recent case in which the tribunal takes a tough approach to HMRC’s failure to comply with an unless order.

David Whiscombe

David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.

Stephen Daly

Dr Stephen Daly, lecturer at the Dickson Poon School of Law (King’s College London), and 2023 KCL law graduates Katarina Lau and Daria Nastasiy, analyse the reported first instance tax judgments to see what they tell us about HMRC’s sanctioning decisions and the taxpayers that appealed these decisions.

Bezhan Salehy

Deep Shah

Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.

Tim Sarson

This month’s update from Tim Sarson (KPMG).

Abby Martin Lisa Rickelton Alex Lewis

HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.

Nuel Oji

Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

Kyle Rainsford

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

Brin Rajathurai James Burton Mitchell Fraser

Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.

Reinhart Devisscher Paul Radcliffe Ramzan Bashir

Current EU withholding tax procedures are costly, inefficient and prone to fraud. Is the Commission’s ‘FASTER’ proposal the answer? Paul Radcliffe, Reinhart Devisscher and Ramzan Bashir (EY) investigate.

Go to page of 430