SETTLEMENTS

Gideon Sanitt Bahar Eken Wai Wan

Gideon Sanitt, Wai Wan and Bahar Eken (Macfarlanes) explain why multinationals operating in the UK should expect a more demanding transfer pricing landscape.

Rupert Shiers

Suzanne Hill

Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.

FTT holds discrimination settlement payment not taxable.

Oliver Marre

Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.

Gordon W Buist

Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.

Tom Wallace

Thomas Wallace (WTT Consulting) explains what advisers need to do to take advantage of the variety of tax treatments that are on offer.

Oliver Marre

Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.

Darren Oswick

Matthew Norris

Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.

Oliver Marre

A recent tribunal decision provides lessons on the settlement provisions, Ramsay and piercing the corporate veil, writes barrister Oliver Marre (5 Stone Buildings).

Clara Boyd

On 2 September 2020, HMRC published Revenue & Customs Brief 12/2020 setting out a change in the VAT treatment of payments made in respect of contract terminations and contractual disputes. HMRC’s new general rule is that most such payments will be...

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