TAX POLICY

Peter Dylewski and Philippe Gamito (KPMG) considers the implications of the AG ruling in Commission v Luxembourg and the future availability of the cost sharing group exemption in the UK and other member states.

David O'Keeffe

David O’Keeffe (Aiglon Consulting) reviews the tribunal decision in Gas Recovery And Recycle Ltd, which considered whether an anticipatory R&D claim could be made before payment had actually been made.

Etienne Wong

Etienne Wong (Old Square Tax Chambers) considers the state of VAT bad debt relief in the UK and its relationship to EU law in the light of the recent Court of Appeal judgment in HMRC v GMAC.

David Smith Economics expert

If Philip Hammond wants to introduce bold tax reforms, he will do so against the backdrop of a sharp rise in government debt, writes David Smith.

Donald L Korb

Andrew Solomon

After last week’s stunning result in the US presidential election, the likelihood of comprehensive tax reform has increased dramatically. Donald L Korb and Andrew Solomon (Sullivan & Cromwell) consider the headline proposals and their prospects.

Shiv Mahalingham

Shiv Mahalingham (Duff & Phelps) identifies key changes to international transfer pricing guidance, regulations and case law that have occurred in the past few months.

Jason Collins

Tori Magill

The proposed corporate offence for failing to prevent tax evasion is now set out in the Criminal Finance Bill, and HMRC has issued revised draft guidance. Jason Collins and Tori Magill (Pinsent Masons) outline the ways a relevant body can manage their exposure to risk.

Mark Middleditch

Mark Middleditch (Allen & Overy) provides this month’s review of tax developments affecting the City.

Conor Quigley

Conor Quigley QC (Serle Court) argues that the Commission’s approach to state aid seems to misunderstand the whole purpose of tax rulings concerning transfer pricing.

Graham Aaronson QC

Graham Aaronson QC (Joseph Hage Aaronson) presents a personal view of tax avoidance in the UK over the past 100 years, looking at the case law and legislation which developed in the first half century, and the social and economic context in which they evolved.

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