ANALYSIS

Cutting edge analysis on tax issues.

Alex Rigby

James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.

Penny Simmons

Penny Simmons (Pinsent Masons) considers the interaction of the IR35, intermediaries and construction industry scheme rules.

Tim Sarson

The international tax world is still dominated by BEPS 2.0 developments, reports Tim Sarson (KPMG). This article includes an update on the national implementation of Pillar Two.

Edward Reed

Thomas Schlee

The BlueCrest salaried members case, three HMRC victories on SDLT and three recent taxpayer wins on penalties. Edward Reed and Thomas Schlee (Macfarlanes) review recent developments in the private client world.

Oliver Marre

Amanda Hardy KC

Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.

Ben Blades

Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).

George Peretz KC

The new Act will be important where there appears to be different tax treatment of competing businesses, writes George Peretz KC (Monckton Chambers), but there is also real concern about enforcement.

Anastasia Nourescu

Matthew Greene

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.

Joshua Carey

Howard Watkinson

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.

Michael Ripley

Hui Ling McCarthy KC

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.

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