ANALYSIS

Cutting edge analysis on tax issues.

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.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.

Constantine Christofi

David Goldberg QC

Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).

Matthew Rowbotham

Many (although not all) of HMRC’s proposals on employee benefit trusts and employee ownership trusts will improve the tax rules, writes Matthew Rowbotham (Lewis Silkin).