ANALYSIS

Cutting edge analysis on tax issues.

Heather Self

Heather Self (Blick Rothenberg) suggests what the main political parties should – and, importantly, should not – include in their manifestos.

Bill Dodwell

Bill Dodwell (OTS) looks back at the work of the Office of Tax Simplification.

Anastasia Nourescu

David Pickstone

Anastasia Nourescu and David Pickstone (Stewarts) consider the pitfalls of HMRC’s newly published ADR guidance and how taxpayers and advisers should approach ADR going forward.

Craig Kirkham-Wilson

Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.

Jack Prytherch

Jack Prytherch (CMS) discusses the key updates from the first report on HMRC’s use of financial institution notices.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

Amanda Tickel Caroline Barraclough James Caldecourt

James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.

Tim Sarson

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

Sarah Bond

Helen Buchanan

Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share their experience of the approach HMRC is taking to unallowable purposes enquiries, in particular under CTA 2009 s 441.

Constantine Christofi

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).

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