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ANALYSIS

Cutting edge analysis on tax issues.

Looking back, nothing dramatic seems to have happened in the VAT world – or perhaps it did, writes Etienne Wong (Old Square Tax Chambers).
Not much happened in 2022, so please do be patient as author Jemma Dick (Clifford Chance) cobbles something together.
As the festive season approaches, what do tax judges dream about in the wee small hours, asks Michael Conlon KC.

The R&D tax credit changes announced in the Autumn Statement 2022 have simply not been thought through, and UK companies in the biotechnology and tech sectors are not happy.

The APPG on responsible tax proposes criminally prosecuting tax advisers for avoidance planning. Craig Kirkham-Wilson (Simmons & Simmons) explains why the report is based on some misguided assumptions.
The Court of Appeal has found decisively for HMRC in Centrica Overseas Holdings Ltd on the basis of the statutory disallowance for management expenses of a capital nature. Benjamin Wonnacott (Ropes & Gray) reviews the judgment and its implications.
The CJEU’s decision has reminded us that privacy rights cannot be ignored, no matter how worthy the aims of the transparency movement, writes James Quarmby (Stephenson Harwood). 
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 (Stewarts) reviews the main protections offered by the European Convention on Human Rights and considers how they apply to tax penalties.
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. 
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