VAT

James Morgan

Caroline Inker and James Morgan (Kirkland & Ellis) consider whether the ruling in A Oy could undermine the assumed VAT neutrality of securitisation structures.

James Le Gallais

Anastasia Nourescu

Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).

Gary Barnett

Karen Bannister

In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.

James Hurst

Fabian Barth

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.

Jenny Batchelor

Ahmed Mobasshir

The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).

Daria Nikitina

Simon Down

Benefit in kind rates remain attractive for electric vehicles, but are only part of the picture. Simon Down and Daria Nikitina (Deloitte) explain why employers should adopt a total cost of operation approach to fleet strategy.

Katie Oliver

Gary Barnett

This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers VAT and transfer pricing after Stellantis Portugal, input tax repayment disputes and a reminder that overcharged VAT cannot normally be reclaimed directly from HMRC by the customer.

Tim Sarson

Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.

Lyndon Firth

Swati Thapa

The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).