TAX-POLICY

Jack Lewis

Sarah Lane

Sarah Lane and Jack Lewis (FTI Consulting) look at the background and the effect of the proposals using worked hypothetical examples.

Peter Stewart

Simon Whitehead

Simon Whitehead and Peter Stewart (Joseph Hage Aaronson) review the recent decision in Six Continents, which considers what foreign profits should receive credit at the foreign nominal rate following an earlier ruling of the CJEU in the FII group litigation.

Karen Cooper

Karen Cooper (Cooper Cavendish) reviews the proposed changes to disguised remuneration and recaps the recent changes to date.

Alasdair Friend

The express aim of the proposed changes is to simplify the current position. However, the draft legislation suggests that the opposite might well be the result. Alasdair Friend (Baker & McKenzie) reviews the consultation document.

Dominic Robertson

Isabel Taylor

Dominic Robertson and Isabel Taylor (Slaughter and May) consider the Apple state aid decision and its impact on other businesses.

Andrew Scott

Andrew Scott (Pinsent Masons) considers the various linguistic concepts in determining taxpayer conduct towards paying tax.

Patrick Cannon

Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.

Lynne Rowland

Lynne Rowland (Kingston Smith) explains the proposed changes to DOTAS hallmarks for inheritance tax.

Perminder Gainda

Josh Lom

Josh Lom and Perminder Gainda (Herbert Smith Freehills) consider the decisions in McQuillan and Castledine, where the tribunals took different approaches to the meaning of ‘ordinary share capital’.

Chris Sanger

Chris Sanger (EY) considers the Forum’s key recommendations on the coalition government’s handling of the tax policy making process in the period up to the election.

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