TAX POLICY ADMINISTRATION

Jisun Choi

Kara Heggs

Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.

Ray McCann

Unless shadow advisers are effectively regulated and HMRC can act closer to real time, we will soon once again be facing calls for regulation of the whole profession, writes Ray McCann.

David Whiscombe

HMRC may have overlooked their own statement of practice which says that such a transfer is in general a disposal, writes David Whiscombe.

Mike Lane

Zoe Andrews

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).

Liam McKay

Adam Craggs

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.

Malcolm Gammie CBE KC

Anthony Inglese

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.

Rebekka Sandwell

Robert Waterson

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).

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