HMRC-GUIDANCE

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).

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).

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.

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.

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.

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance. 

Penny Simmons and Rachel McConnell (Pinsent Masons) focus on the uncertainties that exist regarding the application of the new rules and how these are impacting businesses.