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SETTLEMENTS


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

Nick Wright (Jerroms Miller) considers how the new close company reporting regime changes the risk profile for alphabet shares, dividend planning and employee share arrangements in owner-managed businesses.

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 (5 Stone Buildings) considers the Court of Appeal decision and its implications going forward.
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
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 (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 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.
A recent tribunal decision provides lessons on the settlement provisions, Ramsay and piercing the corporate veil, writes barrister Oliver Marre (5 Stone Buildings).
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