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TAX POLICY ADMINISTRATION
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
When does the ratio of a judgment have no precedential value?
Michael Ridsdale
Gemma Williams
Exceptions to the doctrine of precedent do exist but, as a recent case
illustrates, they will be rarely applied in practice, write Michael Ridsdale and
Gemma Williams (Wedlake Bell).
The taxation of carried interest: where are we now?
Ben Symons
The taxation of private equity executives has become highly politically contentious as we head into the next election. An Opposition policy costing document released in February this year (bit.ly/4dol4do) shows that the Labour Party plans to tax the...
Non-dom reform: the proposals
Rebecca Sheldon
Rebecca Sheldon (Old Square Tax Chambers) considers the proposals from the Conservative Party that give a broad indication as to how the new regime is intended to operate, and what might be expected if the Labour Party wins the General Election.
When tax goes wrong
Michael Thomas KC
The position should be calmly evaluated at an early stage in order to put an
appropriate strategy in place, writes Michael Thomas KC (Pump Court
Tax Chambers). Easy to say in theory, but not always so easy to execute in
practice...
The Construction Industry Scheme and reg 20A: the incredible shrinking policy
Kyle Rainsford
The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).
Dealing with HMRC information notices
Dan Williams
Adam Craggs
HMRC have formidable information gathering powers against which there
are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at
three common types of information notice and the extent to which they can
be challenged.
In conversation with... David Milne KC
David Milne KC
Anthony Inglese
Anthony Inglese CB talks to David Milne KC about life at the Tax Bar and
beyond.
More about the Loan Charge
David Pett
Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister
-style obfuscation, writes David Pett (Temple Tax Chambers).
Back to BlackRock: the Court of Appeal restores order
Helen Buchanan
Sarah Bond
The Court of Appeal judgment restores order, write Sarah Bond and
Helen Buchanan (Freshfields Bruckhaus Deringer).
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594
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CIOT seeks clarification on double remittances
HMRC clamp down on VAT grouping within the care industry
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
Vaccine Research Limited Partnership and another v HMRC
WTGIL Ltd v HMRC
DST was always meant to be temporary, says Exchequer Secretary
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up