ANALYSIS

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).

The FSR extends the Commission’s powers so that it can investigate subsidies granted by non-EU states to undertakings operating in the EU. Sarah Bond, Rob Jones and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explain the operation and implications of this regime.

The government has announced the repeal of the 1.5% stamp tax charge on issuances and certain transfers, with effect from 1 January 2024. David Wilson and Jack Jones (Cooley) review the proposed implementation measures which are currently open for consultation.

With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.