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ANALYSIS

Cutting edge analysis on tax issues.

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.
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.
Card image David Wren Reinhart Devisscher Paul Radcliffe
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).
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