TAX POLICY ADMINISTRATION

The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).

Rob Sharpe

Iarlaith McCarthy-Hann

Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.

Jack Gifford

Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.

Sophie Rhind

Elvira Colomer Fatjo

Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.

Jennifer Plummer

Jennifer Plummer (BDO) considers the requirements for this valuable relief and outlines some of the complexities involved where corporate structures are not straightforward.

Finn Halton

Gregory Price

HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).

Jivaan Bennett

Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.

Ed Wright Alison Lobb Lisa Shipley

Alison Lobb, Lisa Shipley and Ed Wright (Deloitte) outline the Inclusive Framework’s much-awaited ‘side-by-side’ package.

Jonathan Athow

Jonathan Athow, HMRC’s Director General for Customer Strategy and Tax Design, outlines the department’s digital transformation plans, compliance strategy and modernisation agenda for the year ahead.

John Barnett

The Government’s approach to APR and BPR reform combines delay and anti-forestalling in a way that risks serious unintended consequences, writes John Barnett (CIOT).

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