FTT

Zoe Andrews

Mike Lane

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.

Fabian Barth

James Hurst

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Julius Konstantin Berling Liesl Fichardt Emily Au

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) cover the Chancellor’s move to make the foreign PE exemption mandatory, alongside Take 3.9 on film tax relief and the trap of mistaking motive for purpose.

Georgia Hicks

Following the remitted PGMOL decision, barrister Georgia Hicks (Devereux Chambers) explores where the employment status battleground now lies, and why the third stage of the RMC test has become more important than ever.

Katie Oliver

Gary Barnett

This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers VAT and transfer pricing after Stellantis Portugal, input tax repayment disputes and a reminder that overcharged VAT cannot normally be reclaimed directly from HMRC by the customer.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.