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PRIVATE BUSINESS TAXES
The post-election (anti-avoidance) enforcement landscape
Ross Birkbeck
With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
VAT, private school fees and anti-forestalling provisions: how far is too far (back)?
Etienne Wong
Shanzé Shah
Etienne Wong and Shanzé Shah (Old Square Tax Chambers) discuss the extent to which anti-forestalling legislation might challenge prepayments that attempt to preserve the existing VAT treatment of private school fees.
Wealth tax possibilities
Philip Simpson KC
It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
Tax aside? Private investment fund side letters
Ben Jones
,
Deepesh Upadhyay
,
Benjamin Shem-Tov
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds
Sutherland) examine the increasing use of side fund letters in a private
investment funds context and the associated most favoured nations process.
Tax and the energy sector: what’s in store for 2024?
Deeksha Rathi
Edward Milliner
Deeksha Rathi and Edward Milliner (Slaughter and May) reflect on recently announced changes in an area faced with global instability, net zero goals and political change.
The Scottish Budget 2024/25: widening the divergence
Isobel d'Inverno
Alan Barr
Isobel d’Inverno and Alan Barr (Brodies) report on Scotland’s latest Budget, which introduces a new ‘advanced’ rate of income tax.
The taxation of SMEs in 2023
David Whiscombe
Disputes over partnerships, goodwill, distributions and VAT were among some of this year’s key points of interest for SMEs, writes David Whiscombe (BKL).
Single supply and VAT exemption for financial services: insights from JPMorgan
Naima Khalid
Anastasia Nourescu
Naima Khalid (EY) and Anastasia Nourescu (Stewarts) consider the impact
of the recent decision in JPMorgan.
School fee planning: back in the Spotlight
Gordon W Buist
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
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114
EDITOR'S PICK
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
1 /7
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
,
Gabrielle Van der Haegen
2 /7
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
3 /7
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
4 /7
Burlington in the UT: a clearer approach
Kyle Rainsford
5 /7
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
6 /7
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
7 /7
The new Labour government: challenges and opportunities
David Gauke
,
Bezhan Salehy
Beneficial ownership: practical applications
Helen Buchanan
,
Matthew Everett
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The statutory residence test: ten things we find very difficult about you
Claire Weeks
,
Aoife McCauley
Burlington in the UT: a clearer approach
Kyle Rainsford
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Deepesh Upadhyay
,
Dominic Robertson
NEWS
Read all
HMRC manual changes: 26 July 2024
Government’s ‘fiscal lock’ is welcome but ‘rather theatrical’, says IFS
EU Council reiterates concerns over UN framework
OECD’s ICAP documents
XST’s three priorities for HMRC
CASES
Read all
Centrica Overseas Holdings Ltd v HMRC
HMRC v GE Financial Investments
A Outram and another v HMRC
Other cases that caught our eye: 26 July 2024
Finanzamt T II v S
IN BRIEF
Read all
Lease extensions and the 3% surcharge
What next for ISA fractional shares?
HMRC service standards: where next?
SDLT: residential or not?
HMRC service standards: where next?
MOST READ
Read all
The dirty dozen
VAT on private school fees
The statutory residence test: ten things we find very difficult about you
Labour rules out return of pensions lifetime allowance
Reeves rules out emergency Budget