ANALYSIS

Cutting edge analysis on tax issues.

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).

Zoe Andrews

Mike Lane

It is full steam ahead for implementation of the global minimum tax in the UK and the EU, report Mike Lane and Zoe Andrews (Slaughter and May).

David Murphy

David Murphy (BSI Group) explains why, for transfer pricing purposes, the cost influence curve could be a rational starting point for contribution analysis when allocating residual profits.

Folajimi FJ Akinla

Folajimi FJ Akinla (PwC) reviews a recent CJEU ruling which curtails the DAC 6 notification obligation concerning certain tax planning cross-border arrangements.

Ben Charles

Nigel Giles

Augmented profits, associated companies and interaction with QIPs are just some of the issues to consider in advance of the rate change from April, as Nigel Giles and Ben Charles (BDO) explain.

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