ANALYSIS

Cutting edge analysis on tax issues.

Annis Lampard and Karmjit Mader (Deloitte) provide a back to basics guide to HMRC’s framework for resolving civil tax disputes.

Tim Sarson

This month’s review by Tim Sarson (KPMG) includes the latest batch of OECD BEPS releases and Pillar Two implementation updates from around the world.

Stephen Daly

Stephen Daly (King’s College London) reports findings from a recent study suggesting the need for greater transparency and training at HMRC, as well as a rebalancing of the tax administration framework.

Andrew Goodall

Can we expect cuts to IHT? Andrew Goodall reports the latest speculation and announcements on tax proposals from the major political parties.

Tamar Ruiz

Matthew Mortimer

The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.

Kelly Stricklin-Coutinho

New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.

Craig Kirkham-Wilson

Craig Kirkham-Wilson (Simmons & Simmons) examines Measuring Tax Gaps 2023 and predicts more enforcement activity in relation to large businesses.

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.

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