ANALYSIS

Cutting edge analysis on tax issues.

Ian Zeider

Emily Clark

Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in BlueCrest, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?

Alistair Godwin

In light of the Upper Tribunal’s recent decision which took a restrictive view of the substantial shareholding exemption rules, a change to the legislation is now required, writes Alistair Godwin (EY).

Jonathan Athow

Jonathan Athow, HMRC’s director general of customer strategy and tax design, explains why tax simplification matters to HMRC and what they are doing to help deliver it.

Alex Rigby

James Anderson

James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.

Penny Simmons

Penny Simmons (Pinsent Masons) considers the interaction of the IR35, intermediaries and construction industry scheme rules.

Tim Sarson

The international tax world is still dominated by BEPS 2.0 developments, reports Tim Sarson (KPMG). This article includes an update on the national implementation of Pillar Two.

Edward Reed

Thomas Schlee

The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.

Oliver Marre

Amanda Hardy KC

Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.

Ben Blades

Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).

George Peretz KC

The new Act will be important where there appears to be different tax treatment of competing businesses, writes George Peretz KC (Monckton Chambers), but there is also real concern about enforcement.

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