ANALYSIS

Cutting edge analysis on tax issues.

Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.

Adam Craggs

Liam McKay

Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).

Paul Townson

Sophie Mehta

Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.

Helen Buchanan

Sarah Bond

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.

Peter Mason

Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days.

Bryn Reynolds

Gary Barnett

Bryn Reynolds and Gary Barnett (Simmons & Simmons) examine the latest developments affecting VAT, including two CJEU decisions and a significant change to the Retained EU Law Bill.

John Tolman

Emily Szasz

Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the proposals for a new UK stamp tax on securities regime.

Ashley Greenbank

Rhiannon Kinghall Were

While a coordinated roll-out of rules was once an aspiration, the reality is anything but, explain Ashley Greenbank and Rhiannon Kinghall Were (Macfarlanes).

Linus Ostberg

Eli Hillman

Relief for double taxation of carried interest now needs to be found on the other side of the Atlantic. The new accruals regime helps to make this possible, write Eli Hillman and Linus Ostberg (KPMG).

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