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ANALYSIS

Cutting edge analysis on tax issues.

Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.
The key aspects of the Spring Statement affecting private clients and the introduction of the overseas entities register are among this month’s developments reported by Edward Reed and Clare Wilson (Macfarlanes).

John Holt and Callum Grant (PwC UK) summarise the UK tax aspects of M&A transactions with a particular focus on acquisitions of high growth tech businesses.
Helen Mackey and Jannine Nicholas (Eversheds Sutherland) consider the application of the new tax to a UK manufacturer of food packaging.
Card image Steven Effingham Simon Baxter Chris Sanger
Chris Sanger, Steven Effingham and Simon Baxter (EY) examine HMRC’s proposals for a new online sales tax covering ‘new’ forms of retail.
Your quarterly review of developments in the contentious tax world, by Jason Collins and Lauren Redhead (DLA Piper). 
The Supreme Court decision in NCL Investments Ltd and the Court of Appeal decision in Skatteforvaltningen are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May). 
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision. 
Rishi Sunak was lauded for his achievements as chancellor, until his Spring Statement. Will tax reform restore his reputation, David Smith asks.
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