ANALYSIS

Paul Farey (AECOM) considers the impact of a Court of Appeal decision in the long-running Urenco capital allowances case.

Weighing up the competitiveness of different jurisdictions from a corporate tax perspective requires a nuanced analysis. Sarah Osprey (Slaughter and May) sets out the key factors to consider and explains why, with tax, it is rare to find a jurisdiction that is a clear winner.

Heather Self (Blick Rothenberg) reviews the controversy surrounding Nadhim Zahawi’s tax affairs.

Joshua Carey and Marianne Tutin (Devereux Chambers) discuss a recent tribunal decision that highlights why the tax treatment of sums paid under any settlement agreements must be considered carefully.

The EU has introduced far-reaching legislation governing the digital reporting of transactions, write Luigi Lungarella and Nadav Shayovitz (PKF Littlejohn).

Tim Sarson (KPMG) provides a recap of recent Pillar One and Two developments, and looks ahead to what’s in store throughout 2023.

Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).

Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance. 

From a review of recent costs decisions, it is difficult to escape the conclusion that the FTT can be guilty of inconsistency and results-led reasoning when exercising its jurisdiction in relation to costs orders, write Adam Craggs and Harry Smith (RPC). 

A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and Andy Carruthers (Macfarlanes).