CORPORATE TAXES

It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).

Justine Dignam

The latest R&D reforms were said to simplify the tax regime and encourage business investment. The reality though is more complexity, writes Justine Dignam (Markel Tax).

Eloise Walker

Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).

Helen Coward

Lewis Currie

Helen Coward and Lewis Currie (Charles Russell Speechlys) consider the consequences of unlawful distributions by UK companies, including the tax pitfalls to avoid.

Andrew Howard

Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.

Alex Rigby

James Anderson

James Anderson and Alex Rigby (Skadden) examine HMRC’s package of proposed transfer pricing reforms, and consider how they might assist with existing uncertainty and double taxation disputes.

Oliver Marre

Amanda Hardy KC

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).

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