GROUPS

Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.

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.

Dominic Mathon

Dominic Mathon (100 Group Tax Committee) reiterates the urgent need for tax reform to encourage UK investment and boost economic growth.

David Harmer

A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).

Aimee Wilde

Andrew Fitton

Andrew Fitton and Aimee Wilde (UNW) explain why a UK-filed GloBE Information Return for a foreign-parented group may not require detailed information for every jurisdiction in which the group operates.

Ceinwen Rees

Caroline Inker

Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.

Gerald Montagu

Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal decision in Lloyds Asset Leasing Ltd.

Maddy Potthast

Gavin Little

Continuing the series of articles on corporate tax issues, Gavin Little and Maddy Potthast (Interpath) explain the rules for capital gains groups and the pitfalls to watch out for in practice.

Yousuf Chughtai

Davinder Sahota

Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision which shows how complex and large structures can be considered to function as plant for capital allowances purposes, even where other premises-like functions may exist.

Freddie Schwier

Dominic Foulkes

Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.

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