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ANALYSIS

Cutting edge analysis on tax issues.

Matthew Greene and Anastasia Nourescu (Stewarts) explain what the rule 18 lead case procedure is, review recent case law clarifying its scope and set out a few practical tips for advisers.
For the first time the Upper Tribunal has considered the impact and scope of the Ablessio abuse principle for deregistering a taxpayer from VAT. Howard Watkinson and Joshua Carey (Devereux Chambers) examine the judgment and its implications.
Hui Ling McCarthy KC and Michael Ripley (11 New Square) examine the much-awaited Supreme Court judgment on the VAT liability of loan administration services.
The obvious conclusion from the Upper Tribunal decision is that every standalone company should form a dormant subsidiary, writes Robert Langston (Saffery Champness), but there are anti-avoidance rules to consider.
While awaiting the outcome of HMRC’s consultation on stamp tax modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider some missed opportunities and unresolved issues.
The UN is demanding a greater role in setting the global tax policy agenda, but some countries have questioned whether this undermines the OECD/G20 Inclusive Framework discussions. Sarah Blakelock reports.
Tricky timings, difficult delineations, punitive payments... Mike Lane and Zoe Andrews (Slaughter and May) review the latest developments that matter.
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Hotel La Tour, Impact Contracting Solutions and a CJEU decision on deducting overpaid VAT are in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
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