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ANALYSIS

Cutting edge analysis on tax issues.

Matthew Radcliffe (Charles Russell Speechlys) explains why the not so ‘mini-Budget’ will draw close attention from private clients and intermediaries around the world.
There was undoubtedly some good news for business owners, although few specific tax incentives for business owners to invest. Jonathan Hickman (BDO) reports.

The chancellor’s growth plan is reminiscent of Barber’s ‘dash for growth’ 50 years ago. That does not bode well, warns economist Duncan Weldon.

Julie Butler and Fred Butler (Butler & Co Alresford) examine an FTT case that denied a deduction for legal expenditure incurred defending rights to a number of assets ‘collectively’ when one of those assets was sold separately.
The OTS is conducting a review on the emerging trends and tax implications of hybrid and distance working. Moniza Syeda (Tolley) asks whether it is time for the introduction of a commuting allowance in the UK, and she considers what can be learned from elsewhere in Europe.
The Upper Tribunal’s decision on the transfer pricing aspects of the BlackRock case is an overly restrictive interpretation of the law, writes Paul Sutton (LCN Legal).
Elyse Waller and Davinder Sahota (EY) review an Upper Tribunal ruling that provides insight on a term used in numerous places in the tax legislation, as well as demonstrating the importance of witness evidence.
Kyle Rainsford (Norton Rose Fulbright) examines the first UK case about the interpretation of a purpose rule in a double tax treaty which extends the recent approach of Blackrock HoldCo 5 to the international fiscal arena.
Proposed changes to the CGT rules on transfers of property between separating spouses and a tribunal decision on information notices are among the developments reviewed by Edward Reed and Clare Wilson (Macfarlanes).
We should grasp the opportunity to create a stable, coherent, simpler and fair tax system, argues David Martin (formerly Herbert Smith).
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