ANALYSIS

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Bryn Reynolds and Gary Barnett (Simmons & Simmons) examine the latest developments affecting VAT, including two CJEU decisions and a significant change to the Retained EU Law Bill.

Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the proposals for a new UK stamp tax on securities regime.

While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).

Relief for double taxation of carried interest now needs to be found on the other side of the Atlantic. The new accruals regime helps to make this possible, write Eli Hillman and Linus Ostberg (KPMG).

Recent developments that matter from around the globe, reported by Tim Sarson (KPMG).

Martin Shah (Simmons & Simmons) reviews the proposed reserved investor fund regime, while Melville Rodrigues (Apex Group) says why it is needed.

HMRC has released a second consultation on the taxation of decentralised finance cryptoasset lending and staking transactions. David Haworth and Alex Cheetham (Freshfields Bruckhaus Deringer) review the proposals.