ANALYSIS

Cutting edge analysis on tax issues.

James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.

Dominic Robertson

The Upper Tribunal in Hargreaves effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.

Kirsten Hunt

Kitty Swanson

Kitty Swanson and Kirsten Hunt (Mayer Brown) consider some key issues regarding incentivising fund managers in the context of the ongoing debate surrounding carried interest.

Jo Crookshank

Gary Barnett

Jo Crookshank and Gary Barnett (Simmons & Simmons) cover a number of the latest developments in the VAT and indirect tax field.

Anthony Inglese

Former HMRC general counsel Anthony Inglese talks to Alan Evans, the current holder of that role, about his career and current work priorities.

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.

Nick Wright

Pete Miller

Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.

Bezhan Salehy

Sarah Ling

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.