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HMRC guidance
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HMRC guidance
HMRC-GUIDANCE
10 questions on Uncertain Tax Treatment
Abigail McGregor
Steven Porter
Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT
regime after two years of operation.
HMRC’s guidance: what is it good for?
Jack Slater
Sarah Ling
HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).
What is the UK tax treatment of Dubai (DIFC) Foundations?
Will Timbrell
Kyra Motley
There is no equivalent to a Foundation registered with the Dubai International
Finance Centre Registrar of Companies under English law. How then should
they be treated for UK tax purposes? Kyra Motley and Will Timbrell
(Boodle Hatfield) investigate.
Green and pleasant land? VAT and Natural Capital
Joshua Stevens
Brigitte Potts
Brigitte Potts (Evelyn Partners) and Joshua Stevens (Pump Court Tax
Chambers) consider the VAT implications of credits or biodiversity units in
tackling climate change.
US limited liability corporations: updated HMRC guidance
Sebastian Prichard Jones
Andrew Crozier
HMRC’s updated guidance on the treatment of profits arising within, and
distributions from, US LLCs is unsatisfactory in a number of respects, write
Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).
Tax and the City review for January 2024
Zoe Andrews
Mike Lane
Consultation responses to the VAT treatment of fund management services,
Euromoney
on the purpose test, recent developments on Pillar Two, and a report on the tax contribution of the UK banking sector are examined by Mike Lane and Zoe Andrews (Slaughter and May).
Tax and the City review for November 2023
Zoe Andrews
Mike Lane
Target Group
,
Vermilion
and changes to HMRC’s guidance on the double tax
treaty passport scheme are among the developments examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Tax simplification: HMRC’s revised approach
Jonathan Athow
Jonathan Athow, HMRC’s director general of customer strategy and tax
design, explains why tax simplification matters to HMRC and what they are
doing to help deliver it.
Blurred lines: occupation, profession or vocation?
Liesl Fichardt
Emily Au
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Domicile disputes: actions speak louder than words
Hugh Gunson
Louise Paterson
With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
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EDITOR'S PICK
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
1 /7
Freebies
David Whiscombe
2 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
3 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
4 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
5 /7
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
6 /7
SDLT: gardens, grounds and grazing
Max Schofield
7 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
SDLT: gardens, grounds and grazing
Max Schofield
NEWS
Read all
HMRC manual changes: 25 October 2024
Government to consult on new corporate re-domiciliation regime
HMRC revamp guidance on EMI independence test
HMRC confirm delay to new employer reporting requirement
Special tax sites designated in Wales
CASES
Read all
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
R (oao Fluid Systems Technologies (Scotland) Ltd and others) v HMRC
Other cases that caught our eye: 25 October 2024
Panayi v HMRC
BTR Core Fund JPUT v HMRC
IN BRIEF
Read all
‘Arrangements’ that disqualify new EMI option grants
A tale from the frontline of SDLT
Bed and breakfasting before the Budget?
NICs and the Budget
Non-dom reforms: shaping the regime
MOST READ
Read all
Wage protections for seafarers brought into force
HMRC manual changes: 18 October 2024
HMRC update ERS guidance for Vermilion
Is direct effect in VAT still alive in 2024?
Other cases that caught our eye: 18 October 2024