picture-35734.png
The economic substance test
The broader background to the economic substance test is the Inclusive Forum Project to tackle base erosion and profit s...
Fair exchange?
HMRC have extensive information powers. These are contained primarily within Finance Act 2008, Schedule 36....
Considering all outcomes
Barker v Baxendale Walker ([2017] EWCA Civ 2056) This was a civil case against the well-known tax adviser, Paul Baxend...
Most popular reads
Latest briefings
Legal fact or legal fiction?
Some context In an article published in the October 2016 issue of Tax Adviser I discussed forthcoming changes to the ru...
Uncertain future
What is domicile? Domicile is a concept of ‘belonging’ used in tax law, but also elsewhere in the English legal system....
Business Inheritance Tax and Trusts: Where are we now?
Introduction Since 2006 the use of trusts in inheritance tax planning has become progressively more difficult, and less...
Nowhere to hide?
Discovery assessments – under s 29 of the Taxes Management Act 1970 (TMA 1970) – are a perennial concern for tax adviser...
Losing the original
The recent case of Chadda, Nash and Moroney v HMRC [2014] UKFTT 1061 (TC) (Chadda) gives rise to a number of interesting...