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Consultation
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Consultation
CONSULTATION
Notification of uncertain tax treatments: round two
Gregory Price
Jack Slater
Gregory Price and Jack Slater (Macfarlanes) discuss the latest proposals
facing large businesses that require response by 1 June.
Finance Bill 2021: financial institution notices
Elena Rowlands
Ian Zeider
Despite criticism, financial institution notices look set to be introduced.
Elena Rowlands and Ian Zeider (Travers Smith) explore what this could
mean.
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
The European Commission’s ‘digital levy’
Richard Sultman
Jennifer Maskell
The European Commission has a new ‘digital levy’ initiative, pending
international consensus on digital taxation. Jennifer Maskell and Richard
Sultman (Cleary Gottlieb Steen & Hamilton) consider how it might look.
The consultation on VAT grouping
Daniel Johnson
Chris Chatting
Daniel Johnson and Chris Chatting (Deloitte) consider why this issue has
been raised now and what the future changes might be.
The economic crime levy: what’s proposed?
Ali Kazimi
Gavin Helmer
Ali Kazimi and Gavin Helmer (Hansuke) consider the nature of the economic crime levy consultation.
Taxation of credit funds: from one crisis to another
Will Smith
Lily Teh
Will Smith and Lily Teh (
White & Case) consider
some of the major trends and tax issues relevant to the establishment and operation of credit funds.
What exactly is a ‘security’?
Alistair Godwin
Alistair Godwin (
Grant Thornton)
focuses on the Taxes Acts in order to bring out some of the key features of a ‘security’ that are useful in practice.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Is the arm’s length principle dead?
Gary Richards
Robert Hartley
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
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9
EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime