ANALYSIS

Cutting edge analysis on tax issues.

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.

Bryn Reynolds

Gary Barnett

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.

Chris Sanger

In a curiously comforting way, this was a good old fashioned Autumn Statement.

Howard Watkinson

The Upper Tribunal has set a limit on what can be considered a ‘special legal regime’, writes Howard Watkinson (Devereux Chambers).

Helen Adams

Case law on discovery has continued to evolve after the Supreme Court’s judgment in Tooth, as Helen Adams (BDO) explains.

Chancellor Jeremy Hunt delivered his Autumn Statement on 17 November 2022, setting out proposals to address a £55bn gap in the UK’s finances, with half of that amount being raised through increased taxation.

Tim Sarson

The latest on Pillar Two and the European Commission’s consultation on a new common corporate tax system in the EU are among the developments covered in this month’s review, by Tim Sarson (KPMG).

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