ANALYSIS

Cutting edge analysis on tax issues.

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

Heather Self

In this series, Heather Self examines tax issues in the headlines of the national press. This week, she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what the parties say they won’t do, rather than what they will.

Liz Hudson

Jane Duncan

Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of the main parties – with additional comment from the IFS and Tax Policy Associates.

Matthew Greene

Following a recent case, we can probably expect HMRC to be less flexible on taxpayer requests for more time to comply with information notices, writes Matthew Greene (Stewarts).

Clare Wilson

Edward Reed

A new Finance Act and several recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).

Emma Chamberlain

Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.

Pete Hackleton

David Lloyd

HMRC are taking a tougher line on agents’ fees but on some issues they appear to have misunderstood what happens in practice, write David Lloyd and Pete Hackleton (Saffery).

Zoe Andrews

Mike Lane

Kwik-Fit, Hotel La Tour and the FTT decision in Osmond are among the latest developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Reinhart Devisscher

Paul Radcliffe

After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.

Lavina Hassasing

Alistair Nichol

The expected impact of the new Pillar Two regime is starting to unfold as the first UK groups have filed their calendar year-end consolidated accounts, write Alistair Nichol and Lavina Hassasing (Evelyn Partners).

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