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ANALYSIS

Cutting edge analysis on tax issues.

The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.
Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).
There is a discordance between what is said at the despatch box and HMRC’s day-to-day policy, write Jenny Tragner and James Dudbridge (ForrestBrown) in their review of the proposed reforms to the R&D rules.
Penny Simmons (Pinsent Masons) answers a question on the UK tax risks when engaging overseas contractors.
Several recent case decisions in the private client arena, including a challenge to the validity of the loan charge legislation, are examined by Edward Reed and Thomas Simpson (Macfarlanes).
The consultation on hedging risks for future share transactions and the FTT decision in Hargreaves are some of the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Some of the definitions may have changed from DAC 6 to UK MDR, but the concepts are broadly the same, writes Veronica McMahon (Osborne Clarke).
Unsure how the ‘double reasonableness’ test works? Sukhbir Binning and Ian Robotham (Pinsent Masons) provide a refresher guide to this ground-breaking legislation.
Phil Nicklin (CMS Cameron McKenna Nabarro Olswang) reviews the latest proposed changes to the REIT regime which are a significant improvement on the earlier draft measures.

Mark Bevington (ADE Tax) shares his view on the three key challenges taxpayers are currently facing and how their advisers should respond.

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