Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
David Jamieson (Baker McKenzie) reviews the Supreme Court’s ruling on when a supply takes place for VAT purposes, with practical lessons for intra-group invoicing and insights into how UK courts are engaging with CJEU case law post-Brexit.