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HMRC-POWERS

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Rob Sharpe

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Thomas Peet

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

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Sophie Dworetzsky

In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys) examines a case on distributions from an offshore company, a potentially farreaching proposed change to the definition of permanent establishment and the latest HMRC guidance.

Dominic Lawrance

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Sophie Dworetzsky

They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) comment on the end of the remittance basis, the ‘absolute mess’ that is the double remittance situation and a potentially worrying change in HMRC’s view on the taxation of capital payments in ancillary relief on divorce.

HMRC granted permission to amend their statement of case

HMRC’s powers: Soft Drinks Levy

HMRC’s power to deregister where VAT fraud

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Bryn Reynolds

Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.

Revocation of pension protection certificate.

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David Alcock

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Ritchie Tout

David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain why these structures are increasingly under the spotlight.

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Rebekka Sandwell

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Colin Askew

Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.

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EDITOR'S PICK

Rights, influence and LLP member status after BlueCrest

Rights, influence and LLP member status after BlueCrest

Constantine Christofi , Craig Kirkham-Wilson , Lauren Trask

Let the light in: LLCs and other reverse hybrids

Let the light in: LLCs and other reverse hybrids

Matthew Rowbotham

HFFX: the widening reach of miscellaneous income

HFFX: the widening reach of miscellaneous income

Elena Rowlands , Tom Margesson , Ian Zeider

Estoppel and abuse of process in VAT

Estoppel and abuse of process in VAT

Claire Logan

The UK’s tax certainty problem

The UK’s tax certainty problem

Jenny Batchelor , Ahmed Mobasshir

HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf

HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf

Alan Rafferty , Jade Du Berry , Ollie Winters

Ask an expert: Dividend planning under the new close company reporting regime

Ask an expert: Dividend planning under the new close company reporting regime

Nick Wright

Rights, influence and LLP member status after BlueCrest

Rights, influence and LLP member status after BlueCrest

Constantine Christofi , Craig Kirkham-Wilson

Let the light in: LLCs and other reverse hybrids

Let the light in: LLCs and other reverse hybrids

Matthew Rowbotham

HFFX: the widening reach of miscellaneous income

HFFX: the widening reach of miscellaneous income

Elena Rowlands , Tom Margesson

Estoppel and abuse of process in VAT

Estoppel and abuse of process in VAT

Claire Logan

The UK’s tax certainty problem

The UK’s tax certainty problem

Jenny Batchelor , Ahmed Mobasshir

HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf

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

Ask an expert: Dividend planning under the new close company reporting regime

Nick Wright

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