ASSESSMENTS

Constantine Christofi Craig Kirkham-Wilson Chris Sanger

New HMRC measures risk cumulative constitutional and practical effects that piecemeal consultation may fail to reveal, write Chris Sanger, Constantine Christofi and Craig Kirkham-Wilson (EY).

Peter North

Rob Sharpe

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.

David Pett

All but one of the loan charge review’s ‘hard’ recommendations have been accepted. David Pett (Temple Tax Chambers) assesses both the review and the Government’s response – and considers the implications for affected taxpayers and the new settlement opportunity.

Company was ‘trading’ for entrepreneurs’ relief purposes

No landfill tax disposal from licence revocation and dissolution of permit-holder

Daniel Lusted

Daniel Lusted (BDO) examines what’s being proposed.

SDLT assessment and closure notice: The Wool House Ltd v HMRC [2024] UKFTT 997 (TC) (30 October) is quite an administrative tangle. The taxpayer paid SDLT on the normal single-property basis but then put in an overpayment relief claim, on the basis...

Sophie Rhind

Victoria Braid

Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).

R&D tax credits denied: In Strictly Money Ltd v HMRC [2024] UKFTT 866 (TC) (20 September), the judge dismissed the entire R&D claim on the basis that ‘no meaningful work’ was done in respect of the £1.4m expenditure on which...

ADR exit agreement was binding and enforceable.

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