ANALYSIS

Cutting edge analysis on tax issues.

Sean Randall

The SDLT exemptions for alternative property finance need to be updated to give parity with conventional mortgages. Without change, SDLT will distort the market, warns Sean Randall (Blick Rothenberg).

Marc Selby

If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.

Etienne Wong

One step forward for Mr Gove with REULA 2023 and the same step back once the new draft legislation is enacted. Etienne Wong (Old Square Tax Chambers) reviews the government’s proposed bespoke approach for the interpretation of VAT.

Liesl Fichardt

Emily Au

It would seem logical that any asset provided by a company to their employees or directors should be deemed part of their remuneration for tax purposes. However, the legal position is not always so clear, write Liesl Fichardt and Emily Au (Quinn Emanuel).

Gordon W Buist

Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.

Zoe Andrews

Mike Lane

Target Group, Vermilion and changes to HMRC’s guidance on the double tax treaty passport scheme are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).

Nigel Doran

While the Supreme Court judgment in Vermilion provides clarity on some of the questions raised by the deeming rule, it does not touch on questions raised by a number of other common scenarios, writes Nigel Doran (Macfarlanes).

Andrew Howard

Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.

Max Schofield

New reporting requirements for platform operators come into force from 1 January 2024, explains Max Schofield (Devereux Chambers).

Katie Oliver

Gary Barnett

This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers the Supreme Court decision in Target Group, the CJEU ruling on ‘free gift’ promotions, the potential use of split payments in the collection of VAT and the draft legislation intended to ensure stability on the interpretation of VAT and excise laws.

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