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TAX POLICY ADMINISTRATION


A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.
Card image Tom Margesson Elena Rowlands Ian Zeider
A low bar for ‘source’? Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) explain the Supreme Court’s decision in HFFX and its significance for LLP member remuneration.
In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.
The carried interest reforms create substantial compliance burdens and may expose internationally mobile investment managers to double taxation, write Aron Joy and Alex Ereira (Weil, Gotshal & Manges).
Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new Mandatory Tax Adviser Registration Manual.
Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.
‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.
The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).
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