ANTI-AVOIDANCE

Closing a hole that became bigger than expected.

Victoria Hine Steven Porter Leah Fisher

Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).

Jenny Doak

Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with international upheaval.

Eloise Walker

When I originally suggested writing this comment piece, I thought I was going to be writing about exciting changes in partnership taxation, and various other interesting developments in the world of corporate tax. That all went out the window before...

Lynnette Bober

Helen McGhee

There were several measures introduced by the 2025 Budget that will be of particular interest to HNW internationally mobile individuals, and I highlight a few of these below. £5m IHT cap for pre-October 2024 EPTs: There will be a £5m cap...

A detailed report by Lexis®+ UK Tax, with additional practitioner insight.

A report by Lexis®+ UK Tax, with additional practitioner comment.

Tom Wilde

Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.

Carried forward losses: In Blackfriars Hotel (UK) Holdings Ltd v HMRC [2024] UKFTT 1095 (TC) (6 December 2024), the FTT considered an appeal by the taxpayer against a decision of HMRC to deny the use of carried-forward non-trading loan relationship...

Sale of LLP capital accounts not subject to income tax.

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