ANALYSIS

It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.

It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.

Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.

Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).

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.