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DOTAS
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DOTAS
DOTAS
Other cases that caught our eye: 24 May 2024
Discovery assessment on pension scheme charges upheld: L Trachtenberg v HMRC [2024] UKFTT 376 (TC) (9 May) involves another challenge to the scope of the discovery provisions, this time concerning pension scheme unauthorised payments charges...
Other cases that caught our eye: 3 May 2024
Costs decision reversed: Metropolitan International Schools Ltd v HMRC [2024] UKFTT 320 (TC) (10 April 2024) is a slightly odd decision where a FTT judge reversed her own decision about an award of costs against HMRC. The details are probably of...
Contentious tax quarterly: Spring 2024 review
Harry Smith
Adam Craggs
We are seeing a flurry of activity from HMRC on DOTAS and on R&D claims, report Adam Craggs and Harry Smith (RPC).
HMRC v IPS Progression Ltd
FTT imposed £900,000 penalty for six-year late DOTAS disclosure.
The new powers tackling promoters of avoidance schemes
Helen McGhee
Helen McGhee (Joseph Hage Aaronson) considers the new draft provisions
for inclusion in Finance Bill 2021 that strengthen three existing regimes.
The DOTAS conundrum: lessons from Hyrax and Curzon
Cristiana Bulbuc
Lee Ellis
Hyrax
and
Curzon Capital Ltd
consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.
The new DOTAS hallmark for inheritance tax
Lynne Rowland
Lynne Rowland (Kingston Smith) examines the new IHT disclosure rules which took effect from April.
The new EU tax disclosure rules: practical challenges
Brin Rajathurai
Helen Gunson
Brin Rajathurai and Helen Gunson (Freshfields Bruckhaus Deringer) consider practical issues surrounding the new cross-border disclosure rules.
Private client briefing for April 2018
Nicola Simmons
Andrew Goldstone
Andrew Goldstone and Nicola Simmons (Mishcon de Reya) review recent developments in the private client world.
Tax and the City briefing for April 2018
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
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Muller: notional companies and real-world transactions
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Burlington: towards an international fiscal meaning of ‘main purpose’
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Is a loan earnings? Revisiting Rangers
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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’
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Ask an expert: Dividend planning under the new close company reporting regime