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ANALYSIS

Cutting edge analysis on tax issues.

It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.
Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.
Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days. 
Bryn Reynolds and Gary Barnett (Simmons & Simmons) examine the latest developments affecting VAT, including two CJEU decisions and a significant change to the Retained EU Law Bill.
Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the proposals for a new UK stamp tax on securities regime.
While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).
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