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TAX POLICY ADMINISTRATION


Jon Claypole and Jack Sloggett (BDO) welcome HMRC’s new R&D Disclosure Service but explain it is not suitable in all circumstances.
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
Bryn Reynolds (Pinsent Masons) examines the recent Jeffries case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.
Unless shadow advisers are effectively regulated and HMRC can act closer to real time, we will soon once again be facing calls for regulation of the whole profession, writes Ray McCann.
HMRC may have overlooked their own statement of practice which says that such a transfer is in general a disposal, writes David Whiscombe.
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated guidance on share exchanges.
The Grint case illustrates that HMRC may use the sale of occupational income provisions in even vanilla cases of tax planning, writes Oliver Marre (5 Stone Buildings).
Daniel Lusted (BDO) examines what’s being proposed.
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
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