For this month’s edition, Jamshed Bilimoria joins Zoe Andrews to discuss three cases:

  • Hotel La Tour  (Supreme Court judgment on input VAT recovery on deal fees)
  • Tower One St George Wharf (Court of Appeal decision on SDLT and anti‑avoidance)
  • Font (High Court decision on judicial review in MAP dispute)

The podcast then covers aspects of the Autumn Budget and Finance Bill including:

  • Mandatory tax adviser registration
  • SDRT exemption for newly listed companies
  • Reform of transfer pricing and permanent establishment (PE) rules; and the new corporation tax charge replacing DPT
  • Changes to the share for share exchange rules and the impact on clearances

Jamshed and Zoe go on to explore international developments in two areas:

  • The OECD’s global minimum tax “side‑by‑side package” (including new safe harbours and simplification measures)
  • OECD updates on global mobility, including when home‑working may (or may not) create a PE

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