TAX POLICY ADMINISTRATION

Simon Down

Benefit in kind rates remain attractive for electric vehicles, but are only part of the picture. Simon Down and Daria Nikitina (Deloitte) explain why employers should adopt a total cost of operation approach to fleet strategy.

Waqar Shah

HMRC have indicated that they intend to update their litigation and settlement policy later this year. Waqar Shah (Kingsley Napley) considers why the policy is ripe for change.

Kyle Rainsford

What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.

Carolyn Steppler Elena Dunn Alice Martin

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argues that HMRC’s proposed expansion of the UTT regime is the wrong answer to the wrong question, and should be withdrawn.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

Dominic Stuttaford

Katharine Wadia

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 Leah Fisher Steven Porter

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).

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