ANALYSIS

The government’s initial conclusions from its recent response document leave Mark Stapleton and Nicolas Kokkinos (Dechert) doubtful as to whether the stated aim of the review – to make the UK an attractive location for asset managers – will be achieved.

Paul Radcliffe, David Wren and Reinhart Devisscher (EY) consider the next steps for the EU to develop this model, and some key areas which may need to be contemplated in light of the European Commission’s upcoming consultation.

Several recent case decisions in the private client arena, including the correct interpretation of the ‘place of effective management’ tie-breaker test, are examined by Edward Reed and Ross Pizzuti-Davidson (Macfarlanes).

Kate Alexander and Nick Evans (Baker McKenzie) review the newly published Uncertain Tax Treatments by Large Businesses Manual.

Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.

DeFi is encouraging lending and borrowing in the crypto world. Sam Inkersole (BKL) reviews the updates to HMRC’s Cryptoassets Manual.

Paul Aplin OBE looks at how the digital interface between taxpayer and tax authority is changing.

Fiscal conservative first, low tax Tory second? Former Treasury minister David Gauke casts a critical eye on Rishi Sunak.

Sunak has some way to go if he is to join Lawson in the pantheon of chancellors, writes Sam Mitha CBE (former HMRC policy adviser).

The government is expediting legislation on a register of overseas entities that own UK property, write Mukul Chawla QC and Chris Ormond (Bryan Cave Leighton Paisner).