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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.
Tax and the City Review - November 2024 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: the measures in the Autumn Budget which affect financial institutions; the FTT’s decision in GCH where the success of a tax avoidance scheme relied on the taxpayers showing an...
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),...
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...
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...
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...
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...
Tax and the City Review - June 2024 In another case involving both commercial and unallowable purposes, the Court of Appeal in Kwik-Fit decides that some of the loan relationship debits can be allocated to the commercial purpose. In a blow to taxpayers, the Court of Appeal in Hotel La Tour...
BLOG: Lessons learned from JTI and other recent unallowable purpose cases The main lesson to be learned is that it all depends on the specific facts and how they are presented to the fact-finding tribunal! JTI is the third unallowable purpose case decided by the UK Court of Appeal this year, the previous two being BlackRock and...
BLOG: Change: Labour Party Manifesto 2024 Latest polling figures for the UK’s general election on 4 July continue to indicate a change in government as Labour, the main opposition party, enjoys a c. 20 percentage point lead over the Conservative Party which has governed the UK since 2010. What...
Podcast: Tax News: June 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...