Tax News

In 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. Zoe and Tanja also discuss the CJEU’s decisions in the Apple and UK CFC rules State aid cases, the Supreme Court’s decision

In this podcast, Zoe Andrews and Tanja Velling highlight points related to the Chancellor’s statement on public spending inheritance. They also discuss updated HMRC guidance on the multinational top-up tax and domestic top-up tax and comments from the business community. Before moving on to HMRC statistics on the tax take and litigation outcomes for 2023/24, Zoe and Tanja discuss

Join Tanja Velling, co-host of our Tax News podcast and Tax Partners, Dominic Robertson and Charles Osborne, as they discuss the unallowable purpose rule, one of the UK's restrictions on companies deducting interest when calculating profits subject to corporation tax. This episode dives into: How this rule disallows interest deductions where a company’s borrowing is for a main ta

In this podcast, Zoe Andrews and Tanja Velling share thoughts on the IFS publication “The government’s record on tax 2010-24” and HMRC’s estimate of the tax gap for the tax year 2022/23 in the context of Labour’s general election victory. They also discuss the Court of Appeal’s decisions in JTI on the unallowable purpose rule in the loan relationships regime and Altrad

In this podcast, Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in the remuneration trust case Marlborough DP and the VAT classification case Innovative Bites. In considering the latter, Zoe and Tanja also touch on a recent IMF paper with a design proposal for a progressive VAT system. The podcast further covers the Court of Appeal’s judgment in Hotel La T

What does the recent trend of criminalisation of transfer pricing matters in France mean for businesses operating in the country? What tools are tax authorities in France using to obtain information and to enforce the rules? What action can be taken to minimise French transfer pricing risk and what options are available to resolve disputes? Julien Gayral, Partner at Bredin Prat, jo

How do Nigerian tax disputes generally proceed? Should taxpayers continue to comply with the transfer pricing regulations although their validity is in question? How are plans for a tax amnesty likely to develop? Lolade Ososami, Partner at Udo Udoma & Belo-Osagie, joined Sarah Osprey and Tanja Velling to discuss these questions and more. This is the fifth of six episodes in a s

Why is India's tax disputes landscape unique? How should taxpayers best approach dealings with the Indian tax authority? What is the impact on taxpayers of the recent case concerning the most favoured nation clause in Indian tax treaties, including for multinationals taking dividends out of India? Mukesh Butani, Founder and Managing Partner of BMR Legal Advocates, spoke with Sarah

In this podcast, Zoe Andrews and Tanja Velling discuss two Court of Appeal decisions on the loan relationships unallowable purpose rule in section 441 of the Corporation Tax Act 2009: BlackRock and Kwik-Fit. In both cases, the Court of Appeal confirmed the Upper Tribunal’s decision that there was an unallowable tax avoidance purpose. In BlackRock, this led to a complete disallowa

What is the Australian Taxation Office’s approach to tax compliance for multinationals? Does the ATO take into account a wider range of factors than HMRC when considering a settlement? What does the PepsiCo decision mean for the ATO’s expansive definition of “royalties”? Angela Wood, National Practice Group Leader of Clayton Utz Tax Practice, joins Richard Jeens, Co-Head of