Issue 1606

Analysis

• CCO investigations: had the horse already bolted?
• R&D reform: a single RDEC lane for all?
• Tax and the City review for February 2023
• Transfer pricing, residual profits and the cost influence curve
• Legal professional privilege and the DAC 6 notification obligations: the CJEU ruling in Orde van Vlaamse v Vlaamse Regering

In brief

• How can we make non-dom rules fit for purpose?
• New failure to prevent offences coming soon
• Against the grain: the case for saving national insurance
• Anderson: partnerships returns and profit share

News

• Scottish draft regs on non-domestic rates avoidance
• HMRC manual changes: 10 February 2023
• IFS proposes pensions tax reforms
• ATED chargeable amounts increased
• HMRC highlights company share option plan changes
• Tax treatment of public service pensions remedy
• Pension Schemes Newsletter 146
• HMRC drops mandatory plastic packaging tax statements
• GloBE information return will be ‘enormously complex’, says CIOT
• New guidance on Pillar Two GloBE Rules
• OECD releases manual on Multilateral MAPs and APAs
• New MDR guidance published
• New HMRC alternative dispute resolution guidance manual
• CIOT Budget representations on employee expenses and repayment interest
• HMRC raises interest rates again

Cases

• HMRC v Third party and taxpayer
• The King (on the application of Gloucestershire Hospital NHS Foundation Trust v HMRC
• A Lillicrap v HMRC and J Messore (third party)
• Other cases that caught our eye: 10 February 2023

One minute with

• One minute with... Ross Birkbeck

Trackers

• HMRC manual changes: 10 February 2023