UPPER-TRIBUNAL

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.

Henry Bennett-Gough

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.

Adam Craggs

Liam McKay

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Helen Coward

Cristy Ajediti

Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal ruling on the taxation of stock appreciation rights – a decision that introduces fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.

Sinisa Butina

Angela Savin

Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper Tribunal’s reasoning in Scatola and the broader ramifications for taxpayers seeking certainty and finality to their SDLT affairs.

Jo Crookshank

Gary Barnett

This month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers recent decisions on the single/multiple supply rule and the VAT finance intermediation exemption, as well as HMRC’s change of policy on pension scheme costs.

Capital allowances not available for environmental studies expenditure

Capital allowances: ring fence trades and intra-group transfers

Host employer rules: no control needed for NIC liability.

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