TAX POLICY ADMINISTRATION

Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.

In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.

Andrew Howard and Omar Asfar (Ropes & Gray) examine the employment-related securities and valuation lessons from the tribunal’s decision, including the limits of third-party deal pricing and the high bar for protection offered by professional advice.

Adam Craggs and Liam McKay (RPC) review recent procedural decisions on strike out, costs for HMRC’s pre-appeal conduct and disclosure, drawing out the practical risks for tax litigants.

A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.

In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.

Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.