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ANALYSIS

Cutting edge analysis on tax issues.

Former HMRC general counsel Anthony Inglese talks to Alan Evans, the current holder of that role, about his career and current work priorities. 
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.
Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
Hindsight is a wonderful thing but where MTD is concerned, it is not too late to learn from what the recent NAO report reveals, writes Paul Aplin OBE.
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
The Court of Appeal judgment in Bhaur provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
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