Farming LLP’s sideways loss relief fails commerciality test
This tracker shows the current status of, and developments on, consultations (both formal and informal) conducted by the UK government (and other bodies) that have an impact on taxation.
Taxpayer had English domicile of choice
Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.
Collagen drink not zero rated as food for VAT purposes
Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.
Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.
Whether VAT on cost of a car can be recovered
The OECD has announced that the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule (STTR Convention) will enter into force for Albania and San Marino on 1 January 2027. Albania deposited its instrument of...
Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision....
