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PARTNERSHIPS
Partnerships and SP D12
Tanja Velling
Alex Sim
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Taking an interest in partnerships: examining BCG v HMRC
David Haworth
David Haughey
David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.
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).
In conversation with... Rt Hon Lady Justice Falk
Anthony Inglese
Dame Sarah Falk talks to Anthony Inglese CB about her progression from life as a tax practitioner to becoming a senior member of the judiciary.
SDLT and partnerships
Susan Dennis
Adam Kay
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
LLPs and intangibles: avoiding traps in M&A and intra-group transfers
Gregory Price
Lucy Urwin
Gregory Price and Lucy Urwin (Macfarlanes) discuss the challenges of dealing with LLPs in the context of M&A and group reorganisations in light of recent case law.
Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
Deciphering the leaseholder: beating HMRC’s odd habit
Chris Nyland
HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Significantly influential: the BlueCrest salaried members appeal
Oliver Marre
Amanda Hardy KC
The result of the
BlueCrest
appeal represents a good outcome for many businesses structured as LLPs, write Amanda Hardy QC and Oliver Marre (5 Stone Buildings).
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EDITOR'S PICK
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
1 /7
Self’s assessment: Reforms to APR
Heather Self
2 /7
The new Overseas Workday Relief regime: worse than before?
Steve Wade
3 /7
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
4 /7
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
5 /7
Tax Journal's 2024 Autumn Budget coverage
6 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
7 /7
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
,
Rebekka Sandwell
Self’s assessment: Reforms to APR
Heather Self
The new Overseas Workday Relief regime: worse than before?
Steve Wade
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
Tanja Velling
Non-doms post-Budget: where are we now?
Helen McGhee
,
Lynnette Bober
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
NEWS
Read all
HMRC manual changes: 29 November 2024
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
MOST READ
Read all
A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
R (oao Refinitiv Ltd and others) v HMRC
UK signs new double tax treaty with Romania
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
R (oao Cobalt Data Centre 2 LLP and another) v HMRC