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TAX POLICY ADMINISTRATION


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).
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 (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.
There are questions over the use of AI by HMRC under the existing legislation and the adequacy of current taxpayer safeguards, writes Kunal Nathwani (Kirkland & Ellis).
Gerald Montagu and Elmira Jazottes (Gide Loyrette Nouel) consider the importance of the evolving science of memory in tax.
George Gillham and Siobhan Gillespie (Fieldfisher) assess HMRC’s track record.
We are likely to see a consistent increase in the use of mediation in tax disputes. Adam Craggs and Liam McKay (RPC) explain when and how it is in the taxpayer’s interests.
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain why these structures are increasingly under the spotlight.
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
Mainpay should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
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