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ASK AN EXPERT
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Ask an expert: UK IHT issues for US revocable trusts
Jane Johnson
Jane Johnson (Birketts) advises on the IHT consequences of a US trust for US citizens moving to the UK.
Ask an expert: Offshore trusts and trustee borrowing
Julie Howard
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
Ask an expert: Can HMRC override its own statutory review?
Constantine Christofi
Constantine Christofi (RPC) examines the legal and practical issues.
Ask an expert: NRCGT rebasing
Sarah Squires
Sarah Squires (
Old Square Tax Chambers) considers how the
rebasing rules apply to a recent non-resident's plans to sell
UK buy-to-let properties.
Ask an expert: UK company preparing for a Nasdaq listing
Colin Hailey
Colin Hailey (Confluence Tax) outlines two options.
Ask an expert: Plastic packaging tax: ‘finished’ products and exports
Helen Mackey
Jannine Nicholas
Helen Mackey and Jannine Nicholas (Eversheds Sutherland) consider the application of the new tax to a UK manufacturer of food packaging.
Ask an expert: Guernsey limited partnerships - the transparency trap
Matthew Shayle
Matthew Shayle (Wiggin Osborne Fullerlove) highlights a UK tax trap for Guernsey law limited partnerships.
Ask an expert: Moving a UK limited partnership offshore
Katherine Bullock
There are a wide range of tax considerations for a UK resident limited partner, writes Katherine Bullock (Field Court Tax Chambers).
Go to page
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28
EDITOR'S PICK
Freebies
David Whiscombe
1 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
2 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
3 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
4 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
5 /7
SDLT: gardens, grounds and grazing
Max Schofield
6 /7
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
7 /7
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
Much ado about non-doms: the new policy paper
Helen McGhee
,
Lynnette Bober
NEWS
Read all
HMRC manual changes: 4 October 2024
Public opposition to IHT increases remains strong, according to poll
Apprenticeships reforms
Chancellor reflects on non-dom changes
Scottish government consults on new building safety levy
CASES
Read all
D Hill and another v HMRC
C Brzezicki v HMRC
Andrew Quay Hull LLP v HMRC
Other cases that caught our eye: 4 October 2024
Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC
IN BRIEF
Read all
Non-dom reforms: shaping the regime
Non-dom reforms: IHT aspects
EU Watch: new mandate, new tax priorities
More on the Supreme Court’s decision in PGMOL
A bad Apple ruling
MOST READ
Read all
Consultation tracker
EU Watch: new mandate, new tax priorities
HMRC manual changes: 27 September 2024
More on the Supreme Court’s decision in PGMOL
Freebies