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JUST-AND-REASONABLE-APPORTIONMENT

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Neil Fletcher

Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.

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Paul Farey

Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim.

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Jake Landman

Jake Landman (Pinsent Masons) examines the Court of Appeal decision and its wider implications.

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Zoe Andrews

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Mike Lane

The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).

Chris Lallemand

What is a just and reasonable apportionment of profits as an alternative to time apportionment?

EDITOR'S PICK

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

Loopholes and tax avoidance

Loopholes and tax avoidance

Kyle Rainsford

Spare us the cUTTer

Spare us the cUTTer

Nick Thornton

PGMOL: where the FTT decision may be vulnerable on appeal

PGMOL: where the FTT decision may be vulnerable on appeal

Rebecca Seeley Harris

Muller: notional companies and real-world transactions

Muller: notional companies and real-world transactions

Ashley Greenbank

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

Loopholes and tax avoidance

Loopholes and tax avoidance

Kyle Rainsford

Spare us the cUTTer

Spare us the cUTTer

Nick Thornton

PGMOL: where the FTT decision may be vulnerable on appeal

PGMOL: where the FTT decision may be vulnerable on appeal

Rebecca Seeley Harris

Muller: notional companies and real-world transactions

Muller: notional companies and real-world transactions

Ashley Greenbank

CASES

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IN BRIEF

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