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ANALYSIS

Cutting edge analysis on tax issues.

Card image Clara Boyd Lauren Redhead Emily Burke
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds. 
The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
Kitty Swanson and Kirsten Hunt (Mayer Brown) consider some key issues regarding incentivising fund managers in the context of the ongoing debate surrounding carried interest.
Jo Crookshank and Gary Barnett (Simmons & Simmons) cover a number of the latest developments in the VAT and indirect tax field.
Former HMRC general counsel Anthony Inglese talks to Alan Evans, the current holder of that role, about his career and current work priorities. 
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.
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