ANALYSIS

Cutting edge analysis on tax issues.

Sarah Ling

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

Ceinwen Rees

George Apps

Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.

Tim Sarson

Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).

Paul Aplin OBE

Hindsight is a wonderful thing but where MTD is concerned, it is not too late to learn from what the recent NAO report reveals, writes Paul Aplin OBE.

Sean Wright

Deepesh Upadhyay

Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.

Michael Avient

The Court of Appeal judgment in Bhaur provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).

Anne Redston

Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.

Keith Gordon

There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers).

Rebecca Seeley Harris

Rebecca Seeley Harris (Re Legal Consulting) has been campaigning for the regulation of the umbrella company industry and the protection of the worker, under the #FairUmbrella campaign since 2021. Here, she reviews the options for policy change set out in the recent umbrella company consultation.