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IN BRIEF

Views on recent developments in tax.

Card image Nicholas Stretch David O'Keeffe Michael Izza Andrew Gotch Raj Mody Patrick Stevens Ian Stewart Chris Sanger Kevin Cummings Richard Mannion

Eleven tax professionals offer their immediate reaction to the Budget proposals

The Upper Tribunal’s decision in Atlantic Electronics provides useful guidance on the important issue of costs recovery in cases that span the new and old costs rules.

Developments such as the Legal Services Act have hastened the need for legal professional privilege to be extended to clients of tax advisers who are chartered accountants.

Legal professional privilege (LPP) protect

Should publicly listed companies continue to enjoy full confidentiality in respect of their tax affairs?

The recommendations of the Office of Tax Simplification (OTS) for changes to tax-advantaged employee share
schemes, to the extent they are implemented by the government, should make life easier for scheme companies and more incentivising for their employees.

Two recent instances blur the borders between avoidance and evasion, and have potentially changed the tax landscape forever.

The proposed new VAT exemption, while welcome, may prove too difficult for many organisations, particularly groups of smaller, less well-resourced bodies.

A recent FTT decision has resulted in a further reference to the CJEU on the UK’s consortium relief rules and a broad interpretation of the non-discrimination article in the UK/Luxembourg Double Taxation Convention. Taxpayers however need to be wary of how they structure buy-out deals in joint ventures.

The Court of Appeal decision in Lansdowne restricts, significantly, the scope of HMRC’s discovery assessment powers where the taxpayer’s liability turns on a question of law.

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