TAX POLICY ADMINISTRATION

Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).

Martin Shah

Martin Shah (Simmons & Simmons) reviews HMRC’s latest guidance on whether employees of overseas entities working temporarily in the UK give rise to a UK permanent establishment.

Abby Martin Lisa Rickelton Alex Lewis

HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.

Nuel Oji

Stuart Walsh

Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.

Brin Rajathurai James Burton Mitchell Fraser

Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.

Reinhart Devisscher Paul Radcliffe Ramzan Bashir

Current EU withholding tax procedures are costly, inefficient and prone to fraud. Is the Commission’s ‘FASTER’ proposal the answer? Paul Radcliffe, Reinhart Devisscher and Ramzan Bashir (EY) investigate.

Carrie Rutland

Helen Adams

Helen Adams and Carrie Rutland (BDO) provide a practical guide.

Ray McCann

Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.

Peter Mason

Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days.

Sophie Rhind

Victoria Braid

Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal will exercise its power to direct HMRC to issue a closure notice in light of the recent case of Hitchins.

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