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Tax and the City Review - February 2024 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider the possible implications for main purpose tests of the discussion of the meaning of ‘incidental’ by the Court of Appeal in Dolphin Drilling. They also discuss...
Podcast: Tax News: February 2024 In this podcast, Zoe Andrews and Tanja Velling discuss two First-tier Tribunal decisions. One is a fun case and they’ve set this up a mystery to be solved in the first few minutes of the podcast. The other FTT decision is Bolt Services on the VAT...
BLOG: A Dicey Decision – or not really a tax case at all? The spectre of Albert Venn Dicey, the greatest of Victorian constitutionalists, looms large at the feast. In Skatteforvaltningen v Solo Capital Partners, the UK Supreme Court held that the Danish revenue authority (SKAT) was not precluded by reason of...
Tax and the City Review - January 2024 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider the summary of responses to the consultation on the VAT treatment of fund management services and recent developments on Pillar Two, including revised draft guidance from HMRC...
BLOG: The DPT is dead; long live the DPT! Having introduced more than twenty brand-new taxes since the turn of the millennium — at a rate of roughly one new tax per year — did the UK government really announce yesterday the demise of the diverted profits tax (DPT) before it has reached its tenth...
BLOG: Everyone's a winner - but some wins are more substantial than others: latest OECD assessment of the impact of the global minimum tax The global minimum tax is now in effect in the UK for qualifying multinational groups for accounting periods beginning on or after 31 December 2023.  A number of other jurisdictions have also implemented the rules or are in the process of...
Podcast: Tax News: January 2024 In this podcast, Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decision in Harber on the dangers of relying on legal research conducted by generative AI, certain points on tiered partnership structures and the Ramsay doctrine from the...
Tax News Highlights Podcast Archive
BLOG: Cryptoasset reporting: collecting data on the data economy With cryptoassets hitting the news again recently, financial regulators and tax authorities are moving to place a tighter rein on the sector. In October 2023, the UK government confirmed its plans to regulate a much broader swathe of cryptoasset...
BLOG: Stamp duty in the Autumn Statement 2023: update on the 1.5% charge and extension of the growth market exemption The Budget Resolutions published following the Autumn Statement 2023 give temporary statutory effect to provisions intended to remove the UK’s 1.5% stamp duty charge in many circumstances where it would have previously been disapplied under EU law...
Tax Journal – Autumn Statement 2023 Making full expensing – 100% first year capital allowances for investment in qualifying plant and machinery – permanent is the headline corporation tax measure from Autumn Statement 2023. In the Chancellor’s own words : “Worth...
BLOG: R&D Tax in the Autumn Statement 2023: A tale of two regimes For those, like me, who have been following the ever-changing research and development (R&D) tax relief landscape in the UK over the past few years, it will have come as no surprise that the Chancellor, in his Autumn Statement 2023, delivered the...
BLOG: Autumn Statement 2023: ORIP out - UTPR in As trailed on X (previously Twitter), the Chancellor delivered the Autumn Statement on 22 November 2023 with “110 different measures to grow the British economy”. I admit that I have not counted the measures to verify this, but the list of tax measures...
Tax and the City Review for November 2023 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider two Supreme Court decisions: Target Group on the application of the financial services exemption to loan administration services, and Vermilion on the deeming provision in...
Tax and the City Review for October 2023 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider the draft legislation to enact the EU-derived exemption from 1.5% stamp taxes on the issuance and transfer of securities to a clearance service or depositary receipt issuer; and...