ANALYSIS

Cutting edge analysis on tax issues.

Paul Minness

Paul Minness and Alejandro Rivero (RSM UK) assess the scope and practical implications of the new UK-to-UK transfer pricing exemption.

Jonathan Peacock KC

Peter Williams

HMRC say paid entry prize draws are standard rated, but the VAT exemption may not follow Gambling Act classification. Jonathan Peacock KC (11 New Square) and Peter Williams (RSM UK) explain.

Peter North

Rob Sharpe

An obligation to correct tax return inaccuracies is coming. Rob Sharpe and Peter North (Cleary Gottlieb) examine the mechanics and some interpretative uncertainties.

David Ward Richard Miller Daniella Abel

Daniella Abel, Richard Miller and David Ward (Proskauer Rose) review HMRC’s consultation on treaty relief from withholding tax and assess the potential implications for various financing transactions.

Evelyne Bagdassarian Gerald Montagu José Ramón Vizcaíno

A letter from Paris and Madrid, coupled with some reflections on the proposed direct tax Omnibus Directive/Recast DAC 6 Directive and recent Court of Appeal judgments, by Evelyne Bagdassarian, José Ramón Vizcaíno and Gerald Montagu (Stephenson Harwood).

Jo Crookshank

Gary Barnett

Jo Crookshank and Gary Barnett (Simmons & Simmons) review recent VAT developments concerning education, one-off sales, taxi services, the Capital Goods Scheme and online marketplaces.

Georgina West

Georgina West (EY) explains the practical implications of replacing stamp duty and SDRT with the new Securities Transfer Tax.

Louis Triggs

Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.

Elissavet Grout

Hannah Manning

When does preparation become trading? Hannah Manning and Elissavet Grout (Travers Smith) explore why the Upper Tribunal’s Putney Power decision matters for EIS, EMI, SSE and other tax reliefs.