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ANALYSIS

Cutting edge analysis on tax issues.

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.

Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).
The QAHC regime seems a shinier, more flexible, version of the UK’s securitisation company regime. Serena Lee and Matthew Durward-Thomas (Akin Gump) consider how the two regimes interact.
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
A couple of further victories for HMRC on SDLT and a couple of victories for the taxpayer regarding information notices are among the developments reviewed by Edward Reed and Alice Mason (Macfarlanes). 
The Supreme Court’s decision provides useful clarification on two issues arising in VAT disputes. Jake Landman and Abigail McGregor (Pinsent Masons) discuss the practical consequences for taxpayers.
Companies are increasingly turning to voluntary carbon credits to achieve their decarbonisation objectives on the path to ‘net zero’. Oliver Pendred and Andrew Hedges (Baker McKenzie) explain the use and taxation of such credits for UK companies.
The Bill had its second reading in the House of Commons on 25 October. George Peretz KC (Monckton Chambers) looks at what it does and its implications for tax practitioners.
Did the General Court place too much emphasis on legislative technique and too little on substance and effect? Simon Whitehead (Joseph Hage Aaronson) critiques the state aid decision in UK and ITV v Commission.
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