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BLOG: Ramsay reined in? Does the dissent in the UK Supreme Court case of Royal Bank of Canada signal changes to statutory construction principles? What do tax lawyers talk about at lunch? In my case, it’s been the UK Supreme Court's majority decision (4:1) in Royal Bank of Canada. My colleague, Zoe Andrews, has covered the facts and decision in outline here.
BLOG: A question of interpretation: the UK Supreme Court’s decision in Royal Bank of Canada All has ended well for the Royal Bank of Canada (RBC) following the Supreme Court’s majority decision (4:1) that the UK does not have taxing rights over the “royalty” payments RBC received. The value of these payments was dependant on the price and volume...
Podcast: Tax News: February 2025 In this podcast, Tax Associate Nadia Hourihan joins Zoe Andrews and Tanja Velling to discuss the Court of Appeal’s decision in ScottishPower that payments in lieu of penalties are tax deductible (even though no tax deduction would have been available for...
The Trump Effect: US Foreign Tax Policy President Trump did not impose additional tariffs immediately after his inauguration. But among the executive orders that he signed on inauguration day is a firm rebuff of the OECD/G20 Inclusive Framework’s Two-Pillar Solution and the starting point for...
BLOG: Joint ventures does HMRC draft guidance bring clarity? HMRC published supplementary draft guidance on the Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) covering, among other things, joint ventures (JVs). Initial draft guidance in relation to the UK’s implementation of the OECD’s global minimum...
Tax and the City Review - January 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: the Court of Appeal’s decision in Refinitiv on the interaction of diverted profits tax and advance pricing agreements; the FTT’s decision in Syngenta applying the unallowable...
BLOG: Can you get tax deductions for payments in lieu of penalties? The UK Court of Appeal says YES! UK regulators had investigated failings by several energy providers. The investigations were settled with the imposition of nominal £1 penalties and redress payments totalling around £28 million. The nominal penalties were non-deductible for corporation...
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Time to rethink business tax (again)? Over the last year, many businesses will have incurred significant costs in adapting to the new global corporate minimum tax, but following the US election in November 2024, there are concerns about the effectiveness of this measure without US support...
Podcast: Tax News: January 2025 In this podcast, tax associate Alex Sim joins Zoe Andrews and Tanja Velling to discuss the Upper Tribunal’s decision in Muller on the interaction of certain provisions in the intangible fixed assets regime with the rules on the taxation of partnerships...
BLOG: Balancing growth and taxes: the UK government's corporate tax roadmap The announcement of a Spring Statement (rather than another Budget) on 26 March 2025 chimes with the promise of “predictability, stability and certainty” in the UK government’s corporate tax roadmap (which had sat uneasily with the surprise announcement...
BLOG: Purposive interpretation by the UK Supreme Court in Cobalt Data Centre In what appears to be a case confined to the application of the now expired capital allowances regime in respect of “enterprise zones”, the UK Supreme Court in Cobalt Data Centre, once again, gave an important lesson that is always worth bearing in mind...
Podcast: Tax News: December 2024 In this special episode of our Tax News podcast, Zoe Andrews and Tanja Velling asked Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, what U.S. tax policy may look like during a second Trump Administration.
BLOG: Impact of the US election: what does it mean for tax policy? In a special episode of Slaughter and May’s Tax News podcast, we asked Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, what U.S. tax policy may look like during a second Trump Administration. 
BLOG: Partial enquiry notices – thumbs up or thumbs down? Mind the pennies and the pounds will look after themselves” is something my grandmother often said to me in days when pocket money was still dished out in shiny coins!  It seems HMRC has taken heed of this advice, too, in its pursuit of the large...
A new chapter in the unallowable purpose tale: The FTT's decision in Syngenta In Syngenta, the First-tier Tribunal denied interest deductions on a loan created in an intra-group reorganisation under the unallowable purpose rule in CTA 2009 s 441. This case highlights that commercial purposes need to be clearly articulated and that...