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TAX POLICY ADMINISTRATION
Tax risk insurance claims explained
Julian Feiner
W&I and specific tax risk insurance has proliferated and tax claims are
emerging. Julian Feiner (DAC Beachcroft) explains the unique framework
for claims.
Revisiting the boilerplate withholding tax clause via 1962 (and beyond)
Ceinwen Rees
Serene Ho
Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate
clauses exist and why it’s important to check that they are included in
the contract.
The new Labour government: challenges and opportunities
David Gauke
Bezhan Salehy
David Gauke and Bezhan Salehy (Macfarlanes) share their Treasury insights on
the practical challenges facing the new administration.
Contentious tax quarterly: Summer 2024
Adam Craggs
Harry Smith
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
HMRC’s guidance: what is it good for?
Sarah Ling
Jack Slater
HMRC’s guidance is often of limited value in a taxpayer dispute, and there is an increasing trend of HMRC ‘clarifying’ guidance, sometimes with purported retrospective effect. What then is it good for, ask Sarah Ling and Jack Slater (Macfarlanes).
Objects in the rear view mirror
Andrew Parkes
Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.
Rectification in the FTT: the fix for a lack of jurisdiction
Gideon Sanitt
Sophie Rhind
Gideon Sanitt and Sophie Rhind (Macfarlanes) review the decision in
Cooke
and its relevance for taxpayers of the FTT’s ability to consider rectification and rescission arguments.
Self's assessment: fiscal straitjackets
Heather Self
In this series, Heather Self examines tax issues in the headlines of the national press. This week, she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what
the parties say they won’t do, rather than what they will.
General Election 2024: tax in the manifestos
Liz Hudson
Jane Duncan
Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of
the main parties – with additional comment from the IFS and Tax Policy
Associates.
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Following a recent case, we can probably expect HMRC to be less flexible
on taxpayer requests for more time to comply with information notices,
writes Matthew Greene (Stewarts).
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586
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