CORPORATION TAX

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.

David Haughey Sarah Bond Edward Buxton

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.

Eloise Walker

When I originally suggested writing this comment piece, I thought I was going to be writing about exciting changes in partnership taxation, and various other interesting developments in the world of corporate tax. That all went out the window before...

Ravi Ahlawat

Lauren Redhead

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.