ANALYSIS

Cutting edge analysis on tax issues.

Bill Dodwell

Bill Dodwell (OTS) looks back at the work of the Office of Tax Simplification.

Anastasia Nourescu and David Pickstone (Stewarts) consider the pitfalls of HMRC’s newly published ADR guidance and how taxpayers and advisers should approach ADR going forward.

Craig Kirkham-Wilson

Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.

Jack Prytherch

Jack Prytherch (CMS) discusses the key updates from the first report on HMRC’s use of financial institution notices.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.

Caroline Barraclough Amanda Tickel James Caldecourt

James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.

Tim Sarson

The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).

Helen Buchanan

Sarah Bond

Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) share their experience of the approach HMRC is taking to unallowable purposes enquiries, in particular under CTA 2009 s 441.

Constantine Christofi

Adam Craggs

Whilst taking professional advice will usually mean a taxpayer has taken reasonable care, not taking advice does not necessarily mean a taxpayer has been careless, write Adam Craggs and Constantine Christofi (RPC).

Edward Reed

Toby Ney

When is an interest in possession not an interest in possession? The answer to this question is one of several new developments reviewed by Edward Reed and Toby Ney (Macfarlanes).

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