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ANALYSIS

Cutting edge analysis on tax issues.

Hugh Gunson and Guy Bud (Charles Russell Speechlys) examine the Court of Appeal’s decision which has potentially far-reaching consequences for the PAYE system.
Sophie Rhind (Macfarlanes) reports on the game changing amendment to rule 24 of the Upper Tribunal rules.
The judgment reads as something of a ‘whitewash’, supporting the Commission on every ground, write Paul Davison and Helen Buchanan (Freshfields Bruckhaus Deringer). 
Can the sale of a development site marketed with vacant possession meet the conditions for a VAT free TOGC when the purchaser suggests setting up leases with friendly parties? Jonathan de Wilton (Grant Thornton) investigates.
Delay and a lack of political consensus on BEPS feature in this month’s review by Tim Sarson (KPMG).
Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.
Chris Holmes (BDO) and Catherine Morgan (Consilio Consulting) provide a refresher on the workings of this allowance.
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim. 
If a lack of reasonable care is being alleged, it is essential to understand the taxpayer’s mindset when the mistake was made, as well as any steps the taxpayer took to file their return correctly, writes Claire Miles (Willkie Farr & Gallagher).
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