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1 month ago | 
lexology.com | Zoe Andrews |Tanja Velling |Stephanie Mullins
Click here to listen to the audioIn this podcast, tax associate Stephanie Mullins joins Zoe Andrews and Tanja Velling to discuss the UK Supreme Court’s decision in Royal Bank of Canada which could call into question received wisdom on the Ramsay principle of statutory interpretation.
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Jan 15, 2025 | 
taxjournal.com | Mike Lane |Zoe Andrews |Tanja Velling |David Whiscombe
The Court of Appeal in Refinitiv Ltd and others v HMRC [2024] EWCA Civ 1412 dismissed the taxpayer’s judicial review claim seeking to quash or declare unlawful a diverted profits tax (DPT) notice. Refinitiv a UK resident company in the Thomson Reuters group had argued that the DPT notice issued by HMRC in 2018 was incompatible with an advance pricing agreement (APA) entered into for the period from 2008 to 2014.
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Nov 13, 2024 | 
taxjournal.com | Mike Lane |Zoe Andrews |Andrew Marr
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Oct 10, 2024 | 
lexology.com | Zoe Andrews |Tanja Velling |Alex Sim
Click here to listen to the audioIn 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.
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Oct 10, 2024 | 
lexology.com | Zoe Andrews
HMRC’s Transfer Pricing Guidelines for Compliance (GfC7) are promoted as “best practice approaches to transfer pricing to lower risk and avoid common mistakes”. This may sound like helpful “take it or leave it” guidance, but it should be noted that the guidelines (as a form of guidance) form part of HMRC’s “known position” for the purposes of the uncertain tax treatment (UTT) rules.
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Oct 9, 2024 | 
taxjournal.com | Mike Lane |Zoe Andrews |Andrew Marr |Chris Etherington
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Sep 11, 2024 | 
taxjournal.com | Mike Lane |Zoe Andrews |Heather Self |Peter Vaines
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Sep 5, 2024 | 
lexology.com | Zoe Andrews |Tanja Velling
Click here to listen to the audioIn 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 anti-arbitrage rule to be added to the transitional safe harbour. They also discuss updated HMRC guidance on the multinational top-up tax and domestic top-up tax and comments from the business community.
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Jul 18, 2024 | 
lexology.com | Zoe Andrews
To what extent are professional advisory fees associated with the disposal of a loss-making investment deductible as management expenses under section 1219 of the Corporation Tax Act 2009 (CTA 2009)? This was the question before the Supreme Court in Centrica Overseas Holdings Ltd v HMRC. It was accepted by this stage that the fees in question were expenses of management.
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Jul 9, 2024 | 
taxjournal.com | Mike Lane |Zoe Andrews |James Quarmby |Chris Etherington
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