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CORPORATE TAXES
JTI Acquisition: the FTT casts a wide net on unallowable purpose
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a First-tier Tribunal decision that is important for anyone considering inter-group loan structuring.
R&D claims: the triggers for an enquiry
Carrie Rutland
Dawn Register
Carrie Rutland and Dawn Register (BDO) set out the most common reasons why claims can lead to an HMRC enquiry and they advise on how to reduce those risks.
Tax and the City review for May 2022
Zoe Andrews
Mike Lane
An FFT decision on unallowable purpose and a Supreme Court ruling on an EU law challenge are among the developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
How pillar two attacks multinationals’ high tax subsidiaries
Mark Bevington
Mark Bevington (ADE Tax) highlights the ‘traps’ on the operation of the pillar two model rules which might generate a tax charge when none was expected.
Tax and the City review for April 2022
Zoe Andrews
Mike Lane
The Supreme Court decision in
NCL Investments Ltd
and the Court of Appeal decision in
Skatteforvaltningen
are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Tax and the City review for March 2022
Zoe Andrews
Mike Lane
The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Tax and the City review for February 2022
Zoe Andrews
Mike Lane
Revised draft guidance on large business notification of uncertain tax treatment
and the Court of Appeal’s decision in Embiricos are some of the recent
developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Turning theory into practice: implementing pillar two in the UK
Jack Gifford
Chris Sanger
The debate is moving on from theory to nuts and bolts delivery. Chris Sanger and Jack Gifford (EY) examine the UK’s consultation that does little to promote tax simplification.
Profit recognition under GloBE and domestic rules: it’s all in the timing
Bezhan Salehy
Timing differences could affect a group’s effective tax rate as much as permanent differences do, writes Bezhan Salehy (Macfarlanes).
Tax and the City review for January 2022
Zoe Andrews
Mike Lane
The consultation on hedging risks for future share transactions and the FTT
decision in
Hargreaves
are some of the recent developments reviewed by
Mike Lane and Zoe Andrews (Slaughter and May).
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301
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CIOT seeks clarification on double remittances
HMRC clamp down on VAT grouping within the care industry
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
Loan Charge review: call for evidence
FA 2025 review: The new FIG regime: who are the real winners?