COMPLIANCE

Ian Dennis

Chris Sanger

Chris Sanger and Ian Dennis (EY) set out four possible futures for Pillar Two, exploring the competitive implications of the Side-by-Side regime and the practical choices facing heads of tax.

Adam Craggs

Another procedural layer bolted onto an already intricate system.

Alex Ereira

Aron Joy

The carried interest reforms create substantial compliance burdens and may expose internationally mobile investment managers to double taxation, write Aron Joy and Alex Ereira (Weil, Gotshal & Manges).

Thomas Peet

Rob Sharpe

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Adam Craggs

Liam McKay

Adam Craggs & Liam McKay (RPC) report a year marked by tighter procedural frameworks, clarifying case law and an intensified HMRC focus on both avoidance and criminal activity.

Adam Craggs

The mood music surrounding Budget 2025 was notably downbeat over the past few weeks, with many practitioners expressing pessimism about the scope and direction of the expected changes. Given the strained state of the public finances and the...

Lauren Redhead

Ravi Ahlawat

Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when HMRC enquire into deal funding, and provide a practical playbook from first request to resolution.