When is an application to reduce penalties because of ‘special circumstances’ a better bet than ‘reasonable excuse’? Peter Vaines (Squire Patton Boggs) considers a recent tribunal decision.
Barrister Anne Fairpo (Temple Tax Chambers) explains why and how the DPT could apply to real estate transactions.
Amazon is now booking sales through a number of branches in Europe. Jonathan Cooklin and David Wilson (Davis Polk) consider what led to the change and the likely impact.
HMRC is unable to answer FOI request on the Lagarde list, writes John Barnett (Burges Salmon).
Chris Morgan (KPMG) provides a review of recent international tax developments that matter.
Tony Beare (Slaughter and May) examines the recent eagerly anticipated First-tier Tribunal decision of Next Brand Ltd v HMRC on dividend boosters.
If the new government wants to raise tax receipts without raising rates, could changes to payment due dates provide the answer? Andrew Hubbard (Baker Tilly) explains.
Australia, like the UK, has announced new measures countering the diversion of profits by multinationals, writes Heather Self (Pinsent Masons). The measures increase the pressure on the US to engage with the OECD’s BEPS project.
HMRC is right to assert that the ‘no possibilities’ test should be applied immediately after the base loss period for losses from 1 April 2006, but wrong to apply it to periods before that date, writes Peter Cussons (PwC).