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A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Card image Ben Jones, Deepesh Upadhyay, Benjamin Shem-Tov
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds Sutherland) examine the increasing use of side fund letters in a private investment funds context and the associated most favoured nations process.
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
Catherine Hill (Macfarlanes) sets out a series of recommendations for businesses to mitigate adverse tax consequences following lockdown.
Catherine Robins and Sam Wardleworth (Pinsent Masons) review an interesting Upper Tribunal decision on the test for trading, 'golden contracts' and the availability  of enterprise zone allowances and legitimate expectation.

What differences are there between the tax treatments of trade associations and mutual trades? Jackie Wheaton (Moore Stephens) reviews the key points.

Michelle Sloane (RPC) considers key questions on international trade, following the government’s announcement of a ‘hard Brexit’.

The tribunal has issued its decision in Ingenious Film Partners 2 LLP.  Gideon Sanitt (Macfarlanes) reviews the consequences of that decision for investors.

Jackie Wheaton (Moore Stephens) answers a query on the tax considerations when two partnerships merge.

Andrew Levene (BKL) sets out the tax issues on different options for structuring the purchase of freehold property