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Fixed establishment
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Fixed establishment
FIXED-ESTABLISHMENT
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).
The VAT review for July 2024
Gary Barnett
Joao Martinho
Recent VAT decisions on card handling fees, single supply determinations and fixed establishments are reviewed by Joao Martinho and Gary Barnett (Simmons & Simmons).
SC Adient Ltd & Co. KG
VAT and fixed establishments.
The VAT review for September 2023
Craig Kirkham-Wilson
Gary Barnett
Legitimate expectation, directors’ fees, fixed establishments, reforming the TMO... Craig Kirkham-Wilson and Gary Barnett (Simmons & Simmons) examine recent developments in the VAT world.
The VAT review for May 2022
Bryn Reynolds
Gary Barnett
This month’s update by Bryn Reynolds and Gary Barnett (Simmons & Simmons) covers the CJEU ruling on fixed establishments.
A tale of two companies in two cities: the CJEU’s ruling on fixed establishment in Berlin Chemie
Karen Killington
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
VAT grouping disputes: the implications of HSBC
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) examines the Upper Tribunal decision that represents what is likely to be the first major instalment in a series of cases on the VAT grouping of offshore service companies.
The VAT review for July 2021
Nick Cronkshaw
Gary Barnett
Nick Cronkshaw and Gary Barnett (Simmons & Simmons) provide your monthly guide to the latest VAT developments that matter.
The VAT review for June 2020
Jo Crookshank
Gary Barnett
This month's review of recent VAT developments that matter, by Jo Crookshank and Gary Barnett (Simmons & Simmons).
UK tax pitfalls of the foreign company
Laura Hoyland
Elizabeth Emerson
Laura Hoyland and Elizabeth Emerson (White & Case) explain the various bear-traps for a foreign company proposing to do business in the UK.
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’