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TAX POLICY ADMINISTRATION


Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard) revisits the basic principles of interpreting tax treaties in the UK.
The prognosis for international tax reform does not look good, writes Philip Baker KC (Field Court Tax Chambers).
HMRC’s newly published materials raise important questions about how taxpayers are engaging with the UTT regime in practice, writes Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
The International Controlled Transaction Schedule is expected to be introduced in the UK in the foreseeable future. Andrew Stewart and Amy Clarke (BDO) explain how to prepare.
Tax technology adviser Conrad Young considers AI's rapidly increasing role for tax authorities and tax market participants.
The tribunal decision in Currys on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
Alan Evans CB, HMRC’s General Counsel and Director General of the department’s Legal Group, discusses an often overlooked but crucial part to the running of the tax system.
The Temporary Repatriation Facility could create significant tax savings for some. Alice Pearson (Mercer & Hole) highlights some practical considerations and areas of complexity.
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