CORPORATE TAXES

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

Jake Landman

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.

Hiral Bhatt

Hiral Bhatt (Alvarez & Marsal) examines how the new levy will work and uncovers some uncertainties yet to be resolved.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s round-up that includes Spring Finance Bill measures affecting financial services.

Eloise Walker

As contract terminations proliferate in uncertain economic times, Eloise Walker (Pinsent Masons) looks at the tax issues arising from terminating an acquisition before it completes.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.