ANALYSIS

Cutting edge analysis on tax issues.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reflects on the run-up to the Budget and reviews developments on IHT on pensions, cryptoasset compliance and a recent case on corporate residence.

Adam Craggs

Tom Jenkins

Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions on treaty interpretation, deeming provisions and group litigation orders, alongside HMRC’s latest performance figures.

David Haughey

Sarah Bond

Sarah Bond and David Haughey (Freshfields) discuss some of the practical challenges which arise in tax disputes involving partnerships and their members.

Amelia Roffey

Helen Coward

Sweet relief? Helen Coward and Amelia Roffey (Simmons & Simmons) examine recent guidance from the Upper Tribunal on SDLT overpayment claims.

Heather Self

In the first of a new series of interviews with senior HMRC figures, HMRC’s Director for Intermediaries, Rob Jones, speaks to Heather Self about mandatory registration, adviser standards and what the department expects from the profession.

Lisa Shipley

Alison Lobb

Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory foreign branch exemption means for UK businesses.

David Pett

The new loan charge settlement scheme may resolve many cases but offers limited benefits for higher-value cases, writes David Pett (Temple Tax Chambers).

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