TAX POLICY ADMINISTRATION

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

Dominic Stuttaford

Katharine Wadia

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Victoria Hine Leah Fisher Steven Porter

Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).

Paul Farey

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Glyn Edwards

Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.

Nigel Watson

Claire Withers

Nigel Watson and Claire Withers (Burges Salmon) consider the extension of EMI option terms to 15 years and the practical implications for plan design, legacy options and compliance.

Jack Prytherch

Yousuf Chughtai

Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans to widen the UTT regime and the practical implications for taxpayers.

Nigel Doran

Lika Jatoeva

Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated guidance on deferred remuneration for internationally mobile employees and consider the resulting risks of double taxation and NICs mismatches.

Liesl Fichardt

Emily Au

Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.