ANALYSIS

Cutting edge analysis on tax issues.

As the festive season approaches, what do tax judges dream about in the wee small hours, asks Michael Conlon KC.

Colin Hailey

The R&D tax credit changes announced in the Autumn Statement 2022 have simply not been thought through, and UK companies in the biotechnology and tech sectors are not happy.

Craig Kirkham-Wilson

The APPG on responsible tax proposes criminally prosecuting tax advisers for avoidance planning. Craig Kirkham-Wilson (Simmons & Simmons) explains why the report is based on some misguided assumptions.

Benjamin Wonnacott

The Court of Appeal has found decisively for HMRC in Centrica Overseas Holdings Ltd on the basis of the statutory disallowance for management expenses of a capital nature. Benjamin Wonnacott (Ropes & Gray) reviews the judgment and its implications.

James Quarmby

The CJEU’s decision has reminded us that privacy rights cannot be ignored, no matter how worthy the aims of the transparency movement, writes James Quarmby (Stephenson Harwood).

Peter Adriaansen

Pierre-Antoine Klethi

This judgment deals a blow to the European Commission’s state aid investigations concerning tax rulings on transfer pricing, writes Pierre-Antoine Klethi and Peter Adriaansen (Loyens & Loeff).

Anastasia Nourescu

Anastasia Nourescu (Stewarts) reviews the main protections offered by the European Convention on Human Rights and considers how they apply to tax penalties.

Sophie Rhind

Sophie Rhind (Macfarlanes) reviews two recent cases which examine when the tribunal will bar HMRC from proceeding in cases where the department’s delay affects hearings.

Ian Shaw

When does the exercise of discretion result in the loss of beneficial EMI tax treatment? Ian Shaw (Korn Ferry) critiques HMRC’s long-awaited guidance.

Gary Barnett

Bryn Reynolds

Gary Barnett and Bryn Reynolds (Simmons & Simmons) review the Supreme Court’s decision in NHS Lothian Health Board and the CJEU’s ruling in GE Aircraft Engine Services, among other developments.

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