ANALYSIS

Cutting edge analysis on tax issues.

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Kapisha Vyas

Réka Mező

AG Kokott calls for a principled approach to the VAT treatment of transfer pricing adjustments – and questions the legacy of Arcomet, write Kapisha Vyas and Réka Mező (Simmons & Simmons).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) reflect on the judgment in Watts on purposive construction, Ripe on intangible fixed assets, the new Pillar Two safe harbours, and HMRC’s new transfer pricing guidelines.

Iarlaith McCarthy-Hann

Rob Sharpe

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.

Jack Gifford

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Adam Marshall

Adam Marshall (Berthold Bauer VAT Consultants) assesses the FTT’s rejection of HMRC’s narrow reading of Item 5 – and considers the consequences for healthcare staffing models.

Simon York CBE

HMRC are adopting a tougher stance with those who continue to deliberately mislead or refuse to cooperate, despite being in the COP 9/CDF process, writes Simon York CBE (Deloitte).

Edward Buxton David Haughey Sarah Bond

The Finance Bill rules introduce further complexity to the earlier draft provisions and place an unwelcome reliance on HMRC guidance, write Sarah Bond, Edward Buxton and David Haughey (Freshfields).

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

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