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ANALYSIS

Cutting edge analysis on tax issues.

When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).
When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.
Jason Collins and Laura Ford (DLA Piper) take stock of the corporate criminal offence in view of recent statistics showing no charges to date and just nine live investigations.
Card image Ian Rowland Kenneth Nugent Lindsey Copland
HMRC is consulting on a single scheme for R&D tax relief to replace the existing SME and RDEC schemes. The timetable is an ambitious one and much needs to be considered, write Lindsey Copland, Ian Rowland and Kenneth Nugent (Grant Thornton).
It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).
David Murphy (BSI Group) explains why, for transfer pricing purposes, the cost influence curve could be a rational starting point for contribution analysis when allocating residual profits.

Folajimi FJ Akinla (PwC) reviews a recent CJEU ruling which curtails the DAC 6 notification obligation concerning certain tax planning cross-border arrangements. 

Augmented profits, associated companies and interaction with QIPs are just some of the issues to consider in advance of the rate change from April, as Nigel Giles and Ben Charles (BDO) explain.
Four key factors determine whether investments are suitable for remittance basis users from a UK tax perspective, write Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys).
Gary Barnett and Bryn Reynolds (Simmons & Simmons) review the recent FTT decision in HBOS and Lloyds Banking on VAT overpayment interest owing following a legislative error, among other developments.
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