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ANALYSIS

Cutting edge analysis on tax issues.

Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
Hindsight is a wonderful thing but where MTD is concerned, it is not too late to learn from what the recent NAO report reveals, writes Paul Aplin OBE.
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
The Court of Appeal judgment in Bhaur provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers). 
Rebecca Seeley Harris (Re Legal Consulting) has been campaigning for the regulation of the umbrella company industry and the protection of the worker, under the #FairUmbrella campaign since 2021. Here, she reviews the options for policy change set out in the recent umbrella company consultation.
Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for. 
It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.
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