ANALYSIS

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).

Matthew Greene and Frances Lewis (Osborne Clarke) examine HMRC’s victory before the tribunal in the K5K case.

The Court of Appeal’s decision brings refreshed simplicity to a tortured area of the law, write Joshua Carey and Sam Way (Devereux Chambers). 

Matthew Mortimer and Kirsten Hunt (Mayer Brown) explain how the corporate interest restriction regime applies to UK acquisition finance transactions. Straightforward it is not.