ANALYSIS

Cutting edge analysis on tax issues.

Robin Saunders

Phil Roper

Phil Roper and Robin Saunders (KPMG) assess the OECD’s proposed revisions to its Transfer Pricing Guidelines.

Liz Ritchie

Liz Ritchie (Forvis Mazars) considers how taxpayers are responding to the changes to Business Property Relief.

Dr Michael Taylor

Dr Michael Taylor (PwC) explains how the Court of Appeal’s Bolt Services decision narrows the scope of the Tour Operators’ Margin Scheme.

James Morgan

Caroline Inker

Caroline Inker and James Morgan (Kirkland & Ellis) consider whether the ruling in A Oy could undermine the assumed VAT neutrality of securitisation structures.

Richard Jeens

Stephanie Mullins

Stephanie Mullins and Richard Jeens (Slaughter and May) explain how to take control of Sch 36 notices by engaging early with HMRC to narrow scope and responding strategically.

Anastasia Nourescu

James Le Gallais

Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).

Jason Collins

Lauren Redhead

Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.

Jack Prytherch

Yousuf Chughtai

The starting point Under Rule 27 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules, SI 2009/273 (as amended) (the FTT rules), each party in standard or complex cases need only provide the other with a list of documents...

Heather Self

Heather Self (Blick Rothenberg) analyses HMRC’s latest tax gap figures, and explains why annual comparisons can mislead and why compliance activity alone will not close the gap.

Tim Sarson

In this month’s update, Tim Sarson (KPMG) tracks the EU Tax Omnibus and DAC recast proposals, Dutch Box 3 reform and digital services tax debate, noting the political barriers to implementation.

Go to page of 458