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ANALYSIS

Cutting edge analysis on tax issues.

Tim Sarson (KPMG) reports on a flurry of activity across the international tax world and looks ahead at what to expect in 2024.
Paula Ruffell and Astrid Vroom (EY) consider the implications of Refinitiv to transfer pricing methodologies adopted in multiple years and what this means for APAs and DPT assessments more generally.
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
HMRC’s updated guidance on the treatment of profits arising within, and distributions from, US LLCs is unsatisfactory in a number of respects, write Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the current status of the TCGA 1992 s 137 main purpose test.
PPR relief, transfer of assets abroad, information notices and the taxation of finder’s fees are among the topics in this month’s review by Edward Reed and Angus Richardson (Macfarlanes).
As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and Sophie Hatton (Deloitte).
The Court of Appeal’s decision is likely to remain authoritative guidance for some time on the question of how a single complex supply ought to be characterised, writes Sarabjit Singh KC (1 Crown Office Row).
Isobel d’Inverno and Alan Barr (Brodies) report on Scotland’s latest Budget, which introduces a new ‘advanced’ rate of income tax.
Increased digital reporting, the implementation of Pillar Two, potential further reforms to pensions tax... Bill Dodwell, former Tax Director of the Office of Tax Simplification, looks at what’s in store for tax in the year ahead.
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