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.
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 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).