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TAX POLICY ADMINISTRATION


Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.
Emma Rawson (ATT) reviews the MTD for Income Tax regulations, highlighting late legislative changes, complex entry and exit rules, quarterly reporting mechanics, and the wide-ranging exemption regime.
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.
As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers. 
Is the UK’s domestic Permanent Establishment definition reform fair, simple and supportive of growth, or is it, in reality, yet further complexity, asks Nick Thornton (Fried Frank).
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
Card image Tom O’Reilly Jan Kolasa Ben Webster
Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
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