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ANALYSIS

Cutting edge analysis on tax issues.

Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover a Scottish case on the correct VAT treatment of break fees and two decisions in the financial services sphere.
Constantine Christofi (RPC) examines the legal and practical issues. 
HMRC’s revised business test for VAT purposes oversimplifies the law almost to the point of misrepresenting it, writes Etienne Wong (Old Square Tax Chambers).
The OECD has been busy, as Tim Sarson (KPMG) explains.
Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic Consulting) set out a framework when considering the allocation of risks in transfer pricing.
Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields Bruckhaus Deringer) discuss whether the UK terms should be given the broader meaning of the OECD concepts in order to bring greater clarity and reduce the risk of double taxation.
Marvin Reynolds and Lyndon Firth (BDO) provide a refresher guide on the tests for TOGCs for VAT purposes.
The new chancellor has reset expectations with an almost total reversal of his predecessor’s mini-Budget, writes Chris Sanger (EY).
Lexis®PSL Tax and Private Client provide a summary of the key tax announcements made in the chancellor’s emergency statement and subsequent speech delivered to the House of Commons, on 17 October 2022 which unravelled most of the measures announced in the Growth Plan (the ‘mini-Budget’) on 23 September 2022. With practitioner comment and an additional timeline of recent announcements.
Paul Farmer and Simon Whitehead (Joseph Hage Aaronson) consider how fiscal state aid issues should be addressed where the national tax provisions creating the aid are not based on a simple exemption from a standard rate but arise from differential rate regimes and asymmetric taxes. 
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