TAX POLICY ADMINISTRATION

Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can transform document review in tax investigations, highlighting the efficiency gains, practical limitations and importance of expert supervision.

Jill Gatehouse Joe Williams Tom Gardner Emily Szasz

Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) consider how the new duty to correct may present challenges in the context of three common mechanisms for addressing tax risks in M&A transactions.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.

Adam Craggs

Tom Jenkins

Adam Craggs and Tom Jenkins (RPC) examine the proposed criminal offence of making reckless untrue statements to HMRC and the concerns surrounding its scope and safeguards.

Zoe Andrews

Mike Lane

Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions on treaty interpretation, deeming provisions and group litigation orders, alongside HMRC’s latest performance figures.

Heather Self

In the first of a new series of interviews with senior HMRC figures, HMRC’s Director for Intermediaries, Rob Jones, speaks to Heather Self about mandatory registration, adviser standards and what the department expects from the profession.

Lisa Shipley

Alison Lobb

Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory foreign branch exemption means for UK businesses.

David Pett

The new loan charge settlement scheme may resolve many cases but offers limited benefits for higher-value cases, writes David Pett (Temple Tax Chambers).