ANALYSIS

Cutting edge analysis on tax issues.

Keith Gordon

There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers).

Rebecca Seeley Harris

Rebecca Seeley Harris (Re Legal Consulting) has been campaigning for the regulation of the umbrella company industry and the protection of the worker, under the #FairUmbrella campaign since 2021. Here, she reviews the options for policy change set out in the recent umbrella company consultation.

Andrew Crozier

Edward Reed

Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).

Ross Robertson

Chris Holmes

Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for.

Tom Wallace

It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.

Will Scott

It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.

Anastasia Nourescu

Cécile Perrault

Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.

Adam Craggs

Liam McKay

Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).

Paul Townson

Sophie Mehta

Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.

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