TAX POLICY ADMINISTRATION

Is the UK’s domestic Permanent Establishment definition reform fair, simple and supportive of growth, or is it, in reality, yet further complexity, asks Nick Thornton (Fried Frank).

Henry Bennett-Gough

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.

Stephen Daly

AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).

Jan Kolasa Ben Webster Tom O’Reilly

Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.

Nick Thornton

Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.

Helen Coward

‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.

Jack Prytherch

Yousuf Chughtai

The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).

Hartley Foster

Hartley Foster (Addington Chambers) examines the right to obtain information from public authorities such as HMRC, via the Freedom of Information Act 2000, and the restrictions on that right.

Eloise Walker

When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.