ANALYSIS

Cutting edge analysis on tax issues.

Gary Barnett

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).

Oliver Walker

Akash Mehta

Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the current status of the TCGA 1992 s 137 main purpose test.

Edward Reed

Angus Richardson

PPR relief, transfer of assets abroad, information notices and the taxation of finder’s fees are among the topics in this month’s review by Edward Reed and Angus Richardson (Macfarlanes).

Artem Vasyutin

Sophie Hatton

As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).

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