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ANALYSIS

Cutting edge analysis on tax issues.

HMRC’s approach and recent tribunal decisions on mixed member partnership taxation have led to some uncertainty for individual and corporate partners. Liesl Fichardt and Emily Au (Quinn Emanuel Urquhart & Sullivan) assess the current state of play and what can be done to minimise risks.
A consultation on a possible online sales tax and some CJEU cases are among the developments in this month’s review, by Bryn Reynolds and Gary Barnett (Simmons & Simmons).
Having had to deal with a pandemic, was the chancellor yet again forced to sing a tune determined by events or was he able to write his own melody? Chris Sanger (EY) reports.
A Lexis®PSL Tax summary of the key tax-related announcements made with the Spring Statement on Wednesday 23 March 2022.
Paul Farey (AECOM) examines two recent decisions that raise some unique considerations and add to the discussion as to what can qualify for plant and machinery allowances.
HMRC is pushing the boundaries of taxation by taking cases involving small businesses, and is currently making assertions that conflict with its own known interpretation of the law, writes Jonathan de Wilton (Grant Thornton). 
Richard Doran and Julian Balson (EY) examine the First-tier Tribunal’s decision in Cider of Sweden.
There are a wide range of tax considerations for a UK resident limited partner, writes Katherine Bullock (Field Court Tax Chambers).
OECD commentary on the pillar two model rules and the responses to the pillar one public consultations are among the recent developments examined by Tim Sarson (KPMG). 
As we await two Court of Appeal decisions, Georgia Hicks (Devereux Chambers) considers what HMRC’s new approach on the ‘business on own account’ test could mean for taxpayers.
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