ANALYSIS

Cutting edge analysis on tax issues.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

Caroline Barraclough Amanda Tickel James Caldecourt

James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.

Tim Sarson

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

Helen Buchanan

Sarah Bond

Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share their experience of the approach HMRC is taking to unallowable purposes enquiries, in particular under CTA 2009 s 441.

Constantine Christofi

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).

Edward Reed

Toby Ney

When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).

Helena Kanczula

When structuring a UK acquisition, there are a myriad of tax issues to consider, as Helena Kanczula (BKL) explains.

Jason Collins

Laura Ford

Jason Collins and Laura Ford (DLA Piper) take stock of the corporate criminal offence in view of recent statistics showing no charges to date and just nine live investigations.

Ian Rowland Kenneth Nugent Lindsey Copland

HMRC is consulting on a single scheme for R&D tax relief to replace the existing SME and RDEC schemes. The timetable is an ambitious one and much needs to be considered, write Lindsey Copland, Ian Rowland and Kenneth Nugent (Grant Thornton).