CORPORATE TAXES

Oliver Marre

Amanda Hardy KC and Oliver Marre (5 Stone Buildings) examine the first Upper Tribunal judgment on the meaning of ‘significant influence’.

Lorna Jordan

Alison Hughes

Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.

Stephen Daly

Stephen Daly (King’s College London) reports findings from a recent study suggesting the need for greater transparency and training at HMRC, as well as a rebalancing of the tax administration framework.

Kara Heggs

Alex Jupp

The proposed reforms to the diverted profits tax would, if implemented, take some of the venom out of DPT’s ‘sting’, write Alex Jupp and Kara Heggs (Skadden).

A Lexis+ UK Tax report of the key announcements with additional practitioner comment.

Jake Landman

Abigail McGregor

Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.

Bezhan Salehy

Sarah Ling

Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.

Ross Robertson

Chris Holmes

Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for.

Helen Buchanan

Sarah Bond

Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.