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Tax planning
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TAX-PLANNING
Other cases that caught our eye: 25 October 2024
IHT implications under Forfeiture Act: Under the Forfeiture Act 1982, a person who has unlawfully killed another person cannot benefit from that person’s estate. However, where in the opinion of the court the justice of the case requires...
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
Other cases that caught our eye: 30 August 2024
Offshore employment: Bilfinger Salamis UK Ltd v HMRC [2024] UKFTT 736 (TC) (16 August) concerns the so-called host employer rules which apply where the ‘personal services’ of individuals employed by a foreign employer are ‘made...
When tax goes wrong
Michael Thomas KC
The position should be calmly evaluated at an early stage in order to put an
appropriate strategy in place, writes Michael Thomas KC (Pump Court
Tax Chambers). Easy to say in theory, but not always so easy to execute in
practice...
Are trusts an appropriate vehicle to hold shares in a family business?
Hayden Bailey
Hayden Bailey (Boodle Hatfield) considers the use of trusts as part of an ownership strategy for family businesses to enable succession planning.
G Haworth and others v HMRC
Upper Tribunal finds FTT correctly tested place of effective management of trusts.
Incorporation relief and ESC D32: a myriad of uncertainty
Gordon W Buist
Gordon W Buist (EQ Accountants) explains how the publication of
Spotlight 63 on landlord tax planning schemes has exposed a fundamental
flaw with incorporation relief from CGT.
Wholly and exclusively: does a tax motive prevent deductibility?
Ross Birkbeck
Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).
A new era for the UK patent box
Sarah Lord
Andy Jacott
All companies claiming patent box relief are subject to the new nexus regime
from 1 July 2021. Sarah Lord and Andy Jacott (Deloitte) explain how it works.
Tax and technology: horizon scanning
Paul Aplin OBE
Former ICAEW president, Paul Aplin OBE, explores how technology is changing the way we work and the skills we need.
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4
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
Reeves should ‘grasp the nettle’ on tax reform, says IFS
HMRC raise game on football clubs
Conservatives would scrap SDLT, says Badenoch
Tax treatment of cryptoasset exchange traded notes
Trusts & estates return: practical point
CASES
Read all
Mainpay Ltd v HMRC
Dialog Semiconductor Ltd v HMRC
Hippodrome Casino Ltd v HMRC
Other cases that caught our eye: 17 October 2025
GW Martin & Co Ltd and another v HMRC
IN BRIEF
Read all
Taking cover
More on s 455
HMRC’s technical note on RIFs
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
Isle of Wight NHS Trust v HMRC
GfC 13 and the filing position: nothing to see here?
Legislating against promoters of marketed tax avoidance scheme