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Podcast: Tax News: November 2024 In this podcast, Zoe Andrews and Tanja Velling to discuss the government’s policy decision at the Autumn Budget to bring unused pension savings and death benefits into the scope of inheritance tax (with the charge to be administered by pension trustees),...
BLOG: Borders of Smoke and Steel: The UK CBAM Consultation Response In a world where borders are often seen as barriers, greenhouse gases remain unconfined, drifting across seas and skies, untethered to nations or geographies. The United Kingdom is now primed to erect a new type of border: motivated not by exclusion, but...
BLOG: The Autumn Budget 2024: Will the Budget deliver growth in UK energy and infrastructure? On 30 October 2024, the Chancellor, Rachel Reeves, delivered the first Budget under a Labour government since 2010, emphasising in her speech that “the only way to drive economic growth is to invest, invest, invest”. Transport, infrastructure, industry,...
BLOG: Autumn 2024 Budget: Support, prevention and deterrence to close the UK tax gap The Autumn 2024 budget sees the UK’s new Labour government act on a number its pre-election manifesto pledges (discussed here), and intentions stated in its ‘Close the Tax Gap’ document, to decrease the UK’s ‘tax gap’. This is the difference between tax...
Tax and the City Review - October 2024 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: the FTT’s decision in Barclays on eligibility for VAT grouping; the Upper Tribunal’s decision in Muller on the interaction of the taxation of partnership rules with the related...
Podcast: Tax News: October 2024 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...
Ten Questions on the Apple Judgment On 10 September 2024, the CJEU surprised most observers by issuing a final judgment in the Apple State aid case. The judgment endorses the position taken by the European Commission back in 2016, in a way that seems hard to square with other judgments...
Tax and the City Review - September 2024 Mike Lane and Zoe Andrews discuss the Supreme Court’s judgment in Centrica (deductibility of management expenses); the Upper Tribunal’s decision in UBS (PAYE: judicial review of HMRC’s decision not to exercise discretion); what a Labour government might...
Podcast: Tax News: September 2024 In this podcast, Zoe Andrews and Tanja Velling highlight points from the Chancellor’s statement on public spending inheritance and consider some of the draft legislation published for consultation, including in relation to Pillar Two, for an...
Podcast: How does the purpose of your borrowing impact tax deductibility? Tax partners, Dominic Robertson and Charles Osborne, join Tanja Velling, co-host of our regular Tax News podcast, for a special episode to discuss risk mitigation, how an HMRC enquiry in this area might proceed and the potential impact on acquisition...
BLOG: How does the purpose of your borrowing impact tax deductibility? It will come as no surprise that the UK imposes certain restrictions on companies’ ability to deduct interest when calculating the profits that are subject corporation tax.  One of these restrictions is the unallowable purpose rule in section 441 of...
Back to basics: Partnership and SP D12 SP D12 is a useful guide as to how the CGT rules should be expected to apply to partnerships and it fills in important gaps in the legislation. However, in practice it can lead to some surprising results and its non-statutory footing can cause uncertainty...
Tax and the City Review - July 2024 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider the Court of Appeal’s decisions in JTI on the unallowable purpose rule in the loan relationships regime, and in Altrad on the use of the Ramsay principle of construction (as...
BLOG: The capital test for investment management expenses is the same as for trading expenses: UK Supreme Court in Centrica Overseas Holdings Limited To what extent are professional advisory fees associated with the disposal of a loss-making investment deductible as management expenses under section 1219 of the Corporation Tax Act 2009 (CTA 2009)?  This was the question before the Supreme Court...
Podcast: Tax News: July 2024 In this podcast, Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in the remuneration trust case Marlborough DP and the VAT classification case Innovative Bites. In considering the latter, Zoe and Tanja also touch on a recent IMF paper...