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ANALYSIS
Cutting edge analysis on tax issues.
If I could turn back time: encouragement for taxpayers seeking rectification
Arthur Wong
Ben Elliott
Ben Elliott and Arthur Wong (Pump Court Tax Chambers) explain why
there are grounds for optimism for taxpayers seeking to rely on rectification as
a potential means of resolving disputes with HMRC.
Mersey Docks: you’re my wonderwall
Yousuf Chughtai
Davinder Sahota
Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision
which shows how complex and large structures can be considered to function
as plant for capital allowances purposes, even where other premises-like
functions may exist.
Tax and the City review for February 2025
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent tax
developments that matter, including the ruling in ScottishPower and HMRC’s
draft guidance on the multinational top-up tax and domestic top-up tax.
Lifecycle of a transaction: structuring an acquisition
Gemma Grunewald
In the first of a new series on the lifecycle of a transaction – from acquisition
to operation and ultimate exit – Gemma Grunewald (DLA Piper) examines
some of the key considerations for a buyer when structuring an acquisition.
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields) examine the implications of the Court of Appeal’s decision for businesses which are potentially within the scope of the UK’s salaried member rules.
ScottishPower and the limits of von Glehn
Rupert Shiers
Suzanne Hill
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
Introducing CenTax: a new tax research centre
Arun Advani
Andy Summers
Arun Advani and Andy Summers (CenTax) explain how engagement with tax professionals is key to CenTax’s mission, and they outline three principles that will guide its work.
Map making
Paul Aplin OBE
We are promised a Digital Transformation Roadmap setting out how HMRC will be transformed into a digital-first organisation. Paul Aplin OBE hopes it will herald a more collaborative approach from the department.
The VAT review for February 2025
Gary Barnett
Joao Martinho
Joao Martinho and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world, including a CJEU decision which appears to extend the MEO/Vodafone Portugal treatment of contractual termination payments to similar damages payments.
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Donald Simpson reports the view from the 100 Group.
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417
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CIOT seeks clarification on double remittances
HMRC clamp down on VAT grouping within the care industry
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
Loan Charge review: call for evidence
FA 2025 review: The new FIG regime: who are the real winners?