CTA

Paul Rattew

John Endacott and Paul Rattew (PKF Francis Clark) examine proposed reforms to company distributions and the taxation of value extracted by private shareholders.

Andrew Page

Andrew Page OBE (formerly HMRC) argues that the denial of relief for windfarm survey costs exposes a gap between the rules for capital allowances and intangible assets.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Aparna Nathan

The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).

Zoe Andrews

Mike Lane

The latest developments that matter, reported by Mike Lane and Zoe Andrews (Slaughter and May).

Constantine Christofi

Anna Lucey

HMRC’s nudge campaign signals a broader challenge to deductibility under CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).

Ross McGregor

Hannah Manning

In the first of two articles examining the close companies rules, Hannah Manning and Ross McGregor (Travers Smith) explain why it should not be assumed that a company is not close without looking carefully at the relevant legislation.

Hugh Gunson

With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The ‘loans to participators’ rules in...

R&D relief claims denied because operational innovations did not advance overall scientific or technological capability

Payments to an Ireland government agency were not deductible under the loan relationship rules

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