PRIVATE BUSINESS TAXES

May Smith

Emily Szasz

May Smith and Emily Szasz (Freshfields) examine some of the key tax considerations that arise in relation to the transfer of assets into a continuation fund.

Michael Thomas KC

Diversifying ownership will become an increasingly important strategy in light of the new restrictions to APR and BPR, writes Michael Thomas KC (Pump Court Tax Chambers).

Dominic Robertson

Amaury de Galbert

Does the CJEU’s judgment in Apple signify a major shift in tax State aid cases? Or is Apple likely to be a one-off? Amaury de Galbert and Dominic Robertson (Slaughter and May) investigate.

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).

Shanzé Shah

Etienne Wong

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.

Philip Simpson KC

It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).

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.

Deepesh Upadhyay Benjamin Shem-Tov Ben Jones

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.

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.