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Issue 1678
Home
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Issue 1678
Issue 1678
20 September, 2024
Analysis
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Corporation tax rate complexities for corporate LLP members
Private client review for September 2024
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
In brief
A bad Apple ruling
Millionaire migration
The Supreme Court’s decision in PGMOL
News
HMRC manual changes: 20 September 2024
Business Tax Roadmap: stability is key, says CIOT
HMRC’s new transfer pricing guidelines ‘suggest more aggressive approach’
R&D information requirements revised
Fractional shares in ISAs to be allowed
CIOT seeks clarity on ‘ordinary share capital’
ATT highlights pitfalls of FHL abolition
Clarifications required on non-dom proposals
Delay VAT on school fees, says ATT
Zero-rating of caravans
HMRC expands MTT/DTT draft guidance
Judicial Review Guide published
HMRC interest rates require further review, suggests CIOT
New HMRC bank transfer details
Cases
European Commission v Ireland and others
HMRC v Professional Game Match Officials Ltd
Muller UK and Ireland Group LLP and others v HMRC
K McCabe v HMRC
Joined Cases
One minute with
One minute with... Jitendra Patel
Trackers
HMRC manual changes: 20 September 2024
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC to accept Advance Tax Certainty expressions of interest from 1 June
State Opening of Parliament 2026
IHT and pensions from April 2027: HMRC set out operational detail
TRF: clarification on trusts
GAAR Advisory Panel opinion
CASES
Read all
J Krason v HMRC
British Institute of Technology Ltd v HMRC
J Nuttall and another v HMRC
Other cases that caught our eye: 15 May 2026
Professional Game Match Officials Ltd v HMRC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Madsen: discovery assessments
Other cases that caught our eye: 8 May 2026
HMRC’s transfer pricing windfall: one-off or new normal?
M Parker v HMRC
Burlington: towards an international fiscal meaning of ‘main purpose’