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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
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC to accept Advance Tax Certainty expressions of interest from 1 June
State Opening of Parliament 2026
IHT and pensions from April 2027: HMRC set out operational detail
TRF: clarification on trusts
GAAR Advisory Panel opinion
CASES
Read all
J Krason v HMRC
British Institute of Technology Ltd v HMRC
J Nuttall and another v HMRC
Other cases that caught our eye: 15 May 2026
Professional Game Match Officials Ltd v HMRC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Madsen: discovery assessments
Other cases that caught our eye: 8 May 2026
HMRC’s transfer pricing windfall: one-off or new normal?
M Parker v HMRC
Burlington: towards an international fiscal meaning of ‘main purpose’