CORPORATION TAX

David Gordon

Writing on behalf of The 100 Group’s Tax Committee, David Gordon calls for stable business taxes, simpler rules and wider access to advance tax certainty to help the UK compete for investment.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including the latest GloBE package, Hunt on the limits of judicial correction, a timely reminder of the significant contribution made by the financial services, and the UTT implications of HMRC’s VAT guidance on fund management.

Lisa Shipley

Alison Lobb

Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory foreign branch exemption means for UK businesses.

A detailed report by Lexis+® UK Tax, with additional practitioner insight.

Karen Bannister

Gary Barnett

In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.

Andrew Hawley

Andrew Hawley (Crowe UK) weighs the trade-off in HMRC’s CT return reforms: fewer routine ‘what does this mean?’ enquiries on the one hand, more targeted scrutiny of complex and subjective positions on the other.

Ashley Greenbank

Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.

Eloise Walker

When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.

Edward Buxton David Haughey Sarah Bond

The Finance Bill rules introduce further complexity to the earlier draft provisions and place an unwelcome reliance on HMRC guidance, write Sarah Bond, Edward Buxton and David Haughey (Freshfields).

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.

Go to page of 198