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ANALYSIS

Cutting edge analysis on tax issues.

Can we expect cuts to IHT? Andrew Goodall reports the latest speculation and announcements on tax proposals from the major political parties.
The multinational top-up tax regime appears to be endlessly complicated. Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine ten aspects of the regime, including a ten-step process to navigating the rules.
New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.
Craig Kirkham-Wilson (Simmons & Simmons) examines Measuring Tax Gaps 2023 and predicts more enforcement activity in relation to large businesses.
The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).
Domicile disputes, exceptional circumstances, judicial review... Edward Reed and Kathryn Hart (Macfarlanes) review recent developments in the private client world.
In recent years, LLPs have been the focus of ongoing challenges by HMRC – this is to become even more complex as HMRC seek to challenge the nature of a ‘capital’ stake in an LLP. Liesl Fichardt and Emily Au (Quinn Emanuel) examine the key issues.
The Upper Tribunal’s decision in Hotel La Tour feels right and yet somehow also counter-intuitive, writes Etienne Wong (Old Square Tax Chambers).
HMRC’s large business director, Nicole Newbury, outlines the department’s  approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances. 
Sam Wardleworth (Pinsent Masons) examines lessons from a number of tribunal decisions over the past five years.
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