TAX POLICY ADMINISTRATION

When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.

Jane Mellor

HMRC’s latest guidance still leaves key questions unanswered, writes Jane Mellor, Head of Professional Standards at the CIOT and ATT.

Adam Craggs

Liam McKay

The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar Martland hurdle once again, write Adam Craggs and Liam McKay (RPC).

Emily Osborne

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Iarlaith McCarthy-Hann

Rob Sharpe

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.

Jack Gifford

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Finn Halton

Gregory Price

HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).

Jivaan Bennett

Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.

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