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Getting the Deal Through: Tax on Inbound Investment Gareth Miles and Tanja Velling contribute the UK chapter to this publication which provides expert local insight into the regulation of taxation on inbound investments in unfamiliar jurisdictions.
Tax and the City Review for October 2019 Mike Lane and Zoe Andrews review the latest corporation tax statistics; the FTT decision in Potter; the judgments in Fiat and Starbucks; and the recently published HMRC guidance on the hybrid capital instrument rules.
Dispute risk under the OECD Secretariat's “unified approach” In her overview of the OECD Secretariat's "unified approach",  Zoe Andrews mentioned that a robust dispute prevention and resolution mechanism will be needed. 
Getting the Deal Through: Tax Controversy 2020 Richard Jeens is the contributing editor of the 7th edition of this publication which summarises the framework for tax disputes in sixteen different jurisdictions, including the US and the UK. Richard Jeens, Dominic Robertson and Charles Osborne are...
Tax and the City Review for September 2019 Mike Lane and Zoe Andrews consider the decision in Hargreaves Lansdown and the latest cases on tax indemnities. They also look at the UK’s consultation on the implementation of DAC6 and draft legislation following Gallaher.
Dawn raids and data dumps: handling the practical realities of tax disputes In the past, many tax disputes were run as technical debates, where the parties (largely) agreed the facts, the court had little contested evidence to consider, and the focus was on the precise interpretation of the law.  .
What are your losses worth? Subject to a £5m deduction allowance, UK corporation tax payers may use carried-forward income losses against up to only 50% of their profits. In July, the government has published draft legislation to extend this restriction from 1 April 2020 to...
The Transfer Pricing Law Review and UK chapter Preface by Steve Edge and Dominic Robertson for the inaugural edition of The Transfer Pricing Law Review, which aims to give readers a high-level overview of the principal transfer pricing rules in 17 countries. UK chapter by Steve Edge and Orlaith Kane.
UK implementation of DAC 6 The draft regulations to implement EU Directive 2018/822 (DAC 6) in the UK have been published alongside a consultation document. HMRC requests responses by 11 October 2019. Legislation must then be introduced by 31 December 2019 and will be accompanied...
Taxing the new self-employed The question of how the tax regime should adapt to reflect modern working practices is a difficult one. There has been a rise in the number of self-employed since 2000 (which interestingly predates the GIG economy) but the average profits of the...
UK publishes draft legislation and guidance for digital services tax On the same day as the US begins an investigation into whether the 3% digital services tax (DST) adopted by the French is damaging to US businesses with a view to taking retaliatory action, the UK publishes for consultation draft legislation and draft...
Tax and the City Review for July 2019 Mike Lane and Zoe Andrews consider the Upper Tribunal’s decision in Development Securities, the Court of Appeal’s decision in Minera Las Bambas and the FTT’s decision in ANO (No.1) Limited. They also review the latest tax gap figures.
Co-opting digital companies into tax law enforcement Today, The Times reported that some 38,000 online sellers registered for VAT in the UK in 2017-18, compared to 29,000 in the previous year and just 5,000 three years earlier.
Tax and the City Review for June 2019 Mike Lane and Zoe Andrews consider the decisions in Warshaw and Hancock. They also look at the lack of progress made on the UK’s long-term future relationship with the EU as regards financial services. 
Taxing the digital economy: impact assessments will help identify winners and losers The G20 has endorsed the OECD's work programme consisting of the two-pillar approach which was the subject of Tanja Velling's recent post.  The G20’s communiqué shows that there is political support at the highest level for this...