ANALYSIS

Cutting edge analysis on tax issues.

Kara Heggs

Alex Jupp

The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).

Kathryn Hart

Edward Reed

Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.

Liesl Fichardt

Emily Au

In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.

Etienne Wong

The Upper Tribunal’s decision in Hotel La Tour feels right and yet somehow also counter-intuitive, writes Etienne Wong (Old Square Tax Chambers).

Nicole Newbury

HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.

Sam Wardleworth

Sam Wardleworth (Pinsent Masons) examines lessons from a number of tribunal decisions over the past five years.

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the Upper Tribunal decisions in JTI Acquisitions and Hotel La Tour, and HMRC’s latest annual report.

Robert Waterson

Liam McKay

The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).

Anastasia Nourescu

Matthew Greene

Matthew Greene and Anastasia Nourescu (Stewarts) explain what the VAT Terminal Markets Order is, why it is useful and how the government plans to reform it.