Dec 20, 2021 OECD published model Pillar Two GloBE rules By Bezhan Salehy The OECD has today published model provisions for the Pillar Two GloBE rules, which seek to ensure multinationals pay a minimum effective...
Dec 14, 2021 A last minute tax Christmas present? By Bezhan Salehy With Christmas fast approaching, will the OECD be giving the tax community a last minute present in the form of the Pillar Two model...
Dec 14, 2021 No decision? No problem: challenging tax in the High Court By Jackelyn West In most circumstances, a decision issued by HMRC may be appealed to the First-tier Tax Tribunal or, if the dispute raises public law...
Dec 14, 2021 LIBOR transition - impact for trustees By Clare Wilson Jennifer Smithson The London Interbank Offered Rate (LIBOR) is one of the main interest rate benchmarks used in financial markets, determining interest...
Dec 10, 2021 Mind the (interpretation) gap: Governmental attitudes towards "incorrect" legal interpretations By Gideon Sanitt Victoria Braid The Times has recently reported that the Government is seeking to limit the power of the courts to overrule decisions made by ministers...
Dec 10, 2021 Who is the Settlor? By Pippa Goodfellow Can somebody who hasn’t added assets to a trust ever be a settlor? The recent Upper Tribunal (UT) decision in Dunsby v HMRC confirms that...
Dec 06, 2021 Executive power: the FCA implements decision-making reform By Lorna Emson James Reid The FCA recently published a policy statement outlining changes to its decision-making processes, in order to make “faster and more...
Dec 02, 2021 HMRC takes action to improve large business tax administration By Rhiannon Kinghall Were There has been growing recognition that the relationship between large businesses and HMRC has become more strained. It was therefore...
Dec 02, 2021 English law, how smart! English legal system ready to take on smart contract disputes without new legislation By James Popperwell Luke Chinniah The Law Commission has recently published advice to the Government concluding that English common law is sufficiently flexible to deal...
Dec 02, 2021 An unappealing position: lack of clarity in Dunsby v HMRC on when permission to appeal is required By Sophie Rhind The recent Upper Tribunal (UT) case of Dunsby v HMRC [2021] UKUT 0289 (TCC) has raised again the issues that parties face when appealing...
Dec 02, 2021 Tax Day: points for private client practitioners By Paul Hardwick Tuesday was the UK’s second so-called “Tax Day” and, as promised earlier this month, the Government has published various papers,...
Dec 01, 2021 IHT and CGT simplification – meaningful reform off the table following OTS review By Rhiannon Kinghall Were The duo of reviews conducted by the Office of Tax Simplification (OTS) into inheritance tax (IHT) and capital gains tax (CGT) have...
Dec 01, 2021 Transfer pricing: master & local file in, IDS out...for now By Adrian Maasch Yesterday, HMRC released a summary of the main findings of its consultation on "transfer pricing documentation" launched on 23 March...