The litigation in Sempra Metals Ltd v IRC [2007] STC 1559 raised the possibility of claiming compound interest in respect of tax which has been overpaid.
HMRC has published new draft guidance on situations where it will not usually review a company's residence status
Reviewing the impact of Astra Zeneca UK Ltd v HMRC
Michael Bird on CFCs
Graham Airs on foreign branch profits
Philip Fisher on PAYE
Ashley Greenbank on capital distributions
Mark Middleditch on the bank levy
Michael Ludlow, Mike Sufrin, Chris Sanger and John Whiting comment on the coalition Government's tax policy at the end of its first Parliamentary term
Nicholas Gardner, Senior Associate and Chartered Tax Adviser, Ashurst, comments