ANALYSIS

Cutting edge analysis on tax issues.

Jihao Zhang

Consultant Jihao Zhang works through eight scenarios for offshore trusts under the new long-term residence test, covering living and deceased settlors, the IHT tail, transitional protections and the £5m cap.

Amelia Roffey

Henry Bennett-Gough

Stage three of the RMC test is where the real action now lies, writes Henry Bennett-Gough (Simmons & Simmons).

Rebecca Seeley Harris

Rebecca Seeley Harris (Re Legal Consulting) examines the potential grounds on which HMRC could appeal the judgment.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Gideon Sanitt Bahar Eken Wai Wan

Gideon Sanitt, Wai Wan and Bahar Eken (Macfarlanes) explain why multinationals operating in the UK should expect a more demanding transfer pricing landscape.

Lyndon Firth

Swati Thapa

The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).

Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Lombard Odier) considers recent developments affecting tax on trusts, privacy concerns surrounding proposed changes to the Register of Overseas Entities and some key tribunal decisions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

Dominic Stuttaford

Katharine Wadia

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.

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