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Tax and the City Review for April 2023 Mike Lane and Zoe Andrews discuss the FTT’s decision in Muller (application of intangible fixed assets rules to an LLP), the UT’s decision in Prudential (interaction of VAT grouping and time of supply rules) and some Spring Finance Bill...
BLOG: Stamp duty reform proposal published on Tax Administration and Maintenance Day It has become a bit of a tradition that a fiscal statement is followed by a further day of tax-related announcements and publications. The tax administration and maintenance day following the Spring Budget 2023 took place on 27 April 2023 – just in time...
Energy (Oil and Gas) Profits Levy Act 2022 Case comment on the Energy (Oil and Gas) Profits Levy Act 2022
Global Investigations Bulletin (April 2023) Our latest Global Investigations Bulletin for April 2023 is now available. This month, we discuss the “failure to prevent” model for corporate criminal offences, and set out the latest news in global investigations and enforcement actions.
BLOG: Of chicken and eggs… Which comes first? This is the question that faced the Upper Tribunal in respect of the time of supply and VAT grouping rules in Prudential Assurance Company.
Tax and the City Review for March 2023 Mike Lane and Zoe Andrews discuss the CJEU’s judgment in the Gallaher case that the UK’s legislation at the relevant time was compliant with EU law and was proportionate without provision for deferral or payment in instalments. They also...
BLOG: Relief for R&D Expenditure: A Brief Respite or a Change in Strategy? In what feels like an everchanging landscape of UK tax relief on research and development (R&D) expenditure, Chancellor Jeremy Hunt in his Spring Budget 2023 announced further reforms to the UK R&D tax relief regime and hinted at the UK...
BLOG: Because it's all about the base, about the base... Two years' ago I wrote a post entitled "Has the Chancellor really just announced a UK corporation tax rise of over 30%?" the gist of which was that by putting the headline rate of corporation tax up from 19% to 25% without narrowing the tax base the...
BLOG: The UK’s Spring Budget 2023: Tax competitiveness revived? Five days before the UK’s Chancellor Jeremy Hunt unveiled the Spring Budget, the Centre for Policy Studies issued a report on the UK’s declining tax competitiveness, noting that the combination of the rise in the headline corporation tax rate...
Earn-outs in M&A transactions: working hard for capital treatment? Earn-outs are common in M&A transactions and can be an attractive mechanism for many reasons, including for their potential for incentivising senior management. However, where an earn-out does form part of an acquisition and individual shareholders...
Tax and the City Review for February 2023 Mike Lane and Zoe Andrews discuss the UK’s implementation of the global minimum tax, HMRC’s guidance on partial exemption special methods for insurers, and the HBOS and Lloyds case on VAT overpayment interest.
BLOG: GloBE Administrative Guidance In order to achieve consistency, any jurisdiction adopting the global minimum tax or “GloBE” rules has to follow the Model Rules and the Commentary as amended from time to time by Administrative Guidance. This guidance is expected to be issued...
Is tax competition dead? What factors do multinationals take into account? This article considers some of the tax criteria that a corporate group may consider when assessing the location of its parent company and/or operations.
Tax and the City Review for January 2023 Mike Lane and Zoe Andrews discuss the cases of Centrica (expenses of management) and Kwik-Fit (unallowable purpose), the consultation on the VAT exemption for fund management services, amendments to the taxation of reinsurance of BLAGAB and the 2022...
BLOG: International tax reform – now more worth the effort? At a webinar on 18 January, the OECD presented its findings on the impact of international tax reform in advance of the full report which will follow in the coming months.