CORPORATE TAXES

Colin Askew, Matt Cummings, Alisha Kouser

Untangling a business from a group (or single entity) in a tax neutral fashion takes time and care. Colin Askew, Matt Cummings and Alisha Kouser (Eversheds Sutherland) provide a case study considering the tax issues on a partition demerger.

Richard Milnes

Fehzaan Ismail

Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion income under the UK hybrid provisions following a prolonged period of iterative change.

Constantine Christofi

The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).

Robert Langston

Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.

Anne Powell

Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.

Mark Whitehouse

Mairead Cummins

Tax Journal’s recent coverage of the Keighley case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.

Jon Preshaw

Ben Proctor

Significant employment tax charges can arise in certain insolvency situations where there was never an intention for rewards to be provided in connection with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).

Mike Lane

Zoe Andrews

The Court of Appeal’s decision in Dolphin Drilling and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).