TAX POLICY ADMINISTRATION

Zoe Andrews

Mike Lane

This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.

Oliver Marre

The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).

Daniel Lusted

Daniel Lusted (BDO) examines what’s being proposed.

Eloise Walker

It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).

Adam Craggs

Liam McKay

This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.

Anthony Inglese

Malcolm Gammie CBE KC

Malcolm Gammie CBE KC (One Essex Court) is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases. He talks to Anthony Inglese about life at the Tax Bar and beyond.

Robert Waterson

Rebekka Sandwell

Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).

Sam Wardleworth

Steven Porter

The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).

Steve Wade

The proposed reforms to Overseas Workday Relief could have greatly simplified administration for taxpayers, agents and HMRC. Steve Wade (EY) examines what’s actually been proposed.

Tanja Velling

Tanja Velling (Slaughter and May) reviews a significant FTT decision in which the taxpayers were denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule.

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