TAX POLICY ADMINISTRATION

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.

James Le Gallais

Anastasia Nourescu

Parallel HMRC and civil proceedings are best handled not as two separate problems to be dealt with in sequence, but as a single, interconnected strategic challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).

Lauren Redhead

Jason Collins

Legal advice privilege (LAP) remains a vital right for taxpayers, but its boundaries are far from settled. Jason Collins and Lauren Redhead (DLA Piper) examine LAP in a tax context, including the recent decision in Aabar v Glencore which extends privilege to intra-client group communications.

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