TAX POLICY ADMINISTRATION

Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new Mandatory Tax Adviser Registration Manual.

Paul Townson

Chris Holmes

Paul Townson and Chris Holmes (BDO) examine the recent changes which are making the loans to participators regime more onerous for close companies and advisers.

Fabian Barth

James Hurst

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

Ray McCann

Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.

Emily Osborne

‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.

Jenny Batchelor

Ahmed Mobasshir

The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).

Ali Shokoohi

Jenny Tragner

Promising but flawed? Jenny Tragner and Ali Shokoohi (S&W) examine HMRC’s SME R&D assurance pilot, which offers earlier answers on difficult points but whose lengthy form-led design may create fresh uncertainty.

Julius Konstantin Berling Liesl Fichardt Emily Au

Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.

A practical guide by Lexis®+ UK Tax examining when a non-statutory clearance is the right route, how to frame the application and how far HMRC’s response can be relied upon.

Georgia Hicks

Following the remitted PGMOL decision, barrister Georgia Hicks (Devereux Chambers) explores where the employment status battleground now lies, and why the third stage of the RMC test has become more important than ever.

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