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Helen Buchanan, Matthew Everett, Gabrielle Van der Haegen

Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.

Chris Etherington

Raising the rate is unlikely to generate significant revenues.

Tom Wallace

How HMRC’s own policy led to a taxpayer victory.

Thomas Chacko

The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).

Sarah Ling

Jack Slater

HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).

Andrew Parkes

Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.

Joao Martinho

Gary Barnett

Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).

Anthony Inglese

Steve Edge

Anthony Inglese CB talks to practitioner Steve Edge about his career and the changing world of tax.

Sara Morgan

One minute with Sara Morgan, Director at Fieldfisher.

CA overturns UT decision in ‘magic’ capital allowances avoidance scheme.

Shadow Chancellor Rachel Reeves has said that Labour will not impose VAT on private school fees retrospectively if it wins the general election. Speaking at The Times CEO Summit, Reeves said: ‘We’re not going to have a retrospective...

Some planning considerations that don't involve pre-payments.

Signs of a compromise position from Labour?

David Whiscombe

Why you should claim EIS income tax relief, even if you don’t need it.

Claire Weeks

Aoife McCauley

The SRT may be better than the old common law, but there are a number of inconsistencies and ambiguities in the legislation that can make it difficult to apply, write Claire Weeks and Aoife McCauley (Maurice Turnor Gardner).

Gideon Sanitt

Sophie Rhind

Gideon Sanitt and Sophie Rhind (Macfarlanes) review the decision in Cooke and its relevance for taxpayers of the FTT’s ability to consider rectification and rescission arguments.

Constantine Christofi

The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).

Ben Lee

In a sector reliant on software for tax solutions, Ben Lee (Andersen) explores the dangers of placing too much faith in ‘tax calculators’.

HMRC have published Measuring tax gaps 2024 setting out the tax gap statistics for 2022/23.The headline tax gap is 4.8% meaning that, of the total theoretical tax take of £823.8bn, £39.9bn was not collected. This is the first time the...

Paul Johnson

Dan Neidle

Would they really raise £27bn? The Liberal Democrats are proposing a package of tax rises that they claim will raise £27bn in 2028/29. These may look politically attractive: a large sum raised without directly raising taxes on...

Helen Miller

Dan Neidle

No surprises, but a lack of vision?There were no tax surprises in Labour’s manifesto. The biggest promises were the negative ones: no increases in rates of income tax, NI, VAT or corporation tax. The positive ones were small: permanent measures...

LabourLabour party proposals on tax had mostly been pre-announced, with commitments not to raise NICs or the basic, higher or additional rates of income tax or VAT. On corporation tax, Labour pledges to cap the main rate at 25% for the...

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has largely eschewed the FTT’s extensive reliance on UK domestic law cases on ‘purpose’ when determining whether a treaty anti-abuse provision applies.

The Labour Party will not reintroduce the pensions lifetime allowance if it wins the general election, reports BBC News. Rachel Reeves had previously suggested that the LTA would be brought back, with certain exceptions for some key workers (NHS...

Heather Self

In this series, Heather Self examines tax issues in the headlines of the national press. This week, she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what the parties say they won’t do, rather than what they will.

Liz Hudson

Jane Duncan

Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of the main parties – with additional comment from the IFS and Tax Policy Associates.

Matthew Greene

Following a recent case, we can probably expect HMRC to be less flexible on taxpayer requests for more time to comply with information notices, writes Matthew Greene (Stewarts).

The main UK political parties have published their general election manifestos, with a variety of tax announcements included (sometimes hidden) in the detail. Some of the more eye-catching points from the Liberal Democrat and Conservative tax plans...

No error by FTT in applying unallowable purpose rules.

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