TAX POLICY ADMINISTRATION

Peter North

Rob Sharpe

An obligation to correct tax return inaccuracies is coming. Rob Sharpe and Peter North (Cleary Gottlieb) examine the mechanics and some interpretative uncertainties.

Daniella Abel Richard Miller David Ward

Daniella Abel, Richard Miller and David Ward (Proskauer Rose) review HMRC’s consultation on treaty relief from withholding tax and assess the potential implications for various financing transactions.

Georgina West

Georgina West (EY) explains the practical implications of replacing stamp duty and SDRT with the new Securities Transfer Tax.

Louis Triggs

Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.

Hannah Manning

Elissavet Grout

When does preparation become trading? Hannah Manning and Elissavet Grout (Travers Smith) explore why the Upper Tribunal’s Putney Power decision matters for EIS, EMI, SSE and other tax reliefs.

Lydia Hutchinson

Ben Clarke

Lydia Hutchinson and Ben Clarke (Birketts) review recent SDLT mixed-use cases and the limits of relying on grazing, agricultural use or future plans.

Phil Roper

Robin Saunders

Phil Roper and Robin Saunders (KPMG) assess the OECD’s proposed revisions to its Transfer Pricing Guidelines.

Dr Michael Taylor

Dr Michael Taylor (PwC) explains how the Court of Appeal’s Bolt Services decision narrows the scope of the Tour Operators’ Margin Scheme.

James Morgan

Caroline Inker

Caroline Inker and James Morgan (Kirkland & Ellis) consider whether the ruling in A Oy could undermine the assumed VAT neutrality of securitisation structures.

Stephanie Mullins

Richard Jeens

Stephanie Mullins and Richard Jeens (Slaughter and May) explain how to take control of Sch 36 notices by engaging early with HMRC to narrow scope and responding strategically.

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