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With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
Just as we contemplate the demise of the remittance basis, Oliver Marre (5 Stone Buildings) examines the first Upper Tribunal decision on a key provision on those rules.
Recent decisions on intra-group VAT services, loan relationship debits and distributions from non-UK resident company are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
The Supreme Court does strive to find a workable and straightforward interpretation of the law, writes Constantine Christofi (EY).
Have HMRC been pushing their interpretation of tax legislation too far? Jason Collins and Ravikaran Ahlawat (DLA Piper) look at lessons from some of this year’s key judgments.
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
Court of Appeal confirms share exchange anti-avoidance rule did not apply.
The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and Jack Gifford (EY).