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ANALYSIS

Cutting edge analysis on tax issues.

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Craig Kirkham-Wilson

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Gary Barnett

Legitimate expectation, directors’ fees, fixed establishments, reforming the TMO... Craig Kirkham-Wilson and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world.

Martin Shah

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

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Sophie Rhind

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Victoria Braid

Sophie Rhind and Victoria Braid (Macfarlanes) examine a recent case in which the tribunal takes a tough approach to HMRC’s failure to comply with an unless order.

David Whiscombe

David Whiscombe asks whether it is fair for a taxpayer to be effectively taxed twice on the basis of a mutually exclusive analysis of the same transaction.

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Stephen Daly

Dr Stephen Daly, lecturer at the Dickson Poon School of Law (King’s College London), and 2023 KCL law graduates Katarina Lau and Daria Nastasiy, analyse the reported first instance tax judgments to see what they tell us about HMRC’s sanctioning decisions and the taxpayers that appealed these decisions.

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Bezhan Salehy

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Deep Shah

Bezhan Salehy and Deep Shah (Macfarlanes) review the government’s extensive package of proposals that touch most areas of the UK’s transfer pricing, permanent establishment and diverted profits tax legislation.

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Tim Sarson

This month’s update from Tim Sarson (KPMG).

Abby Martin Lisa Rickelton Alex Lewis

HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.

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Nuel Oji

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Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

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Kyle Rainsford

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

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EDITOR'S PICK

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

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