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IN BRIEF

Views on recent developments in tax.

... and how recent events have thrown the structured timetable into disarray.
What do two recent case decisions tell us?
HMRC’s heavy-handed approach risks undermining investment in legitimate R&D, while failing to properly investigate wrongdoing.

The big question in Brussels for the autumn is whether or not an agreement on the minimum taxation (Pillar Two) Directive can be achieved. Hungary remains the main outstanding obstacle, and the patience of other EU member states and the European Commission is running thin.

A personal reflection.
Changes of government have often led to less substantial divergences in tax policy than one might think.
What does this mean for employers?
A recent Upper Tribunal decision gives cause for concern.
If the CEST tool is completed and a contrary view is taken, HMRC must be notified.
There is a potential additional hurdle to clear if interest on intra-group debt is to be tax deductible in the UK.
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