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PARTNERSHIPS

David Whiscombe

Boulting cannot be regarded as a satisfactory case, except as to its outcome in favour of the taxpayer, writes David Whiscombe.

Upper Tribunal rules on payments under LLP ‘capital interests’ and the mixed member partnership rules

Redress payment taxable as post-cessation receipt

No entitlement to deductions for amortisation of purchased goodwill

No SDLT due on distributions of partnership and its properties following purchase of JPUT holding structure.

High Court dismisses claim for declaratory relief in relation to failed film partnership scheme

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Michael Ridsdale

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Gemma Williams

Michael Ridsdale and Gemma Williams (Wedlake Bell) illustrate how to ensure certainty of tax treatment on the structuring of a residential property development.

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David Haworth

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David Haughey

David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.

Each week, Tax Journal reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.

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Susan Dennis

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Adam Kay

The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.

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EDITOR'S PICK

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’

Nick Thornton

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency

Hartley Foster

Hotel La Tour: where next for input tax recovery on share disposals?

Hotel La Tour: where next for input tax recovery on share disposals?

Rupert Shiers , Laura Hodgson

Mandatory agent registration: what we know so far

Mandatory agent registration: what we know so far

Jane Mellor

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Permanent Establishment reform: what has changed, who is affected and why does it matter?

Rob Sharpe , Iarlaith McCarthy-Hann

The Pillar Two Side-by-Side package: how UK groups should approach compliance

The Pillar Two Side-by-Side package: how UK groups should approach compliance

Jack Gifford

Share reorganisations: new anti-avoidance rules explained

Share reorganisations: new anti-avoidance rules explained

Peter Morley , Jamie Robson

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