TAX POLICY ADMINISTRATION

Alice Martin Elena Dunn Carolyn Steppler

Alice Martin, Elena Dunn and Carolyn Steppler (Charles Russell Speechlys) consider the UK tax and practical risks arising from offshore trust loans, including unexpected IHT exposure, settlor charges and the consequences of irrecoverable debts.

Ben Elliott

Louis Triggs

Ben Elliott and Louis Triggs (Pump Court Tax Chambers) set out the three conditions for invoking the Inco principle, the factors that determine its application in practice, and the role it may play as Brexit-era drafting and rapid legislative change generate more disputes.

Nick Thornton

Nick Thornton (Fried Frank) argues that HMRC’s proposed expansion of the UTT regime is the wrong answer to the wrong question, and should be withdrawn.

Andrew Hawley

Andrew Hawley (Crowe UK) weighs the trade-off in HMRC’s CT return reforms: fewer routine ‘what does this mean?’ enquiries on the one hand, more targeted scrutiny of complex and subjective positions on the other.

Kyle Rainsford

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

Katharine Wadia

Dominic Stuttaford

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

Victoria Hine Steven Porter Leah Fisher

Recent judgments provide clear warnings that the tribunals will look beyond the contractual labels in offshore arrangements to the underlying reality of who benefits from and controls the workforce, write Leah Fisher, Steven Porter and Victoria Hine (Addleshaw Goddard).

Paul Farey

Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.

Glyn Edwards

Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.

Nigel Watson

Claire Withers

Nigel Watson and Claire Withers (Burges Salmon) consider the extension of EMI option terms to 15 years and the practical implications for plan design, legacy options and compliance.

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