The capital gains tax treatment for lost deposits: three recent cases
Contracts for the sale of interests in land commonly provide for completion by the payment by the purchaser of the outst...
Management of taxes
Management of taxes
A review of cases that have gone to the GAAR panel: what can we learn?
The UK General Anti Abuse Rule (GAAR) was introduced in April 2013 (and applies to arrangements entered into on or after...
How to reduce the burden of tax returns upon millions of self-employed taxpayers
One of the best series of events – at least in my view(!) – is the History of Tax events run by the Worshipful Company o...
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The demystification of decentralised finance: finding our way through
HMRC introduced updated guidance on crypto assets on 2 February 2022, looking at the world of decentralised finance (DeF...
Penetrating the obscuring mists of judicial precedent
In the December 2016 issue of Tax Adviser, my article ‘Return of the naïve’ looked at the Upper Tribunal case of Hardy v...
Making Tax Digital for Income Tax: how will we fit it all in?
I have been following the progress of Making Tax Digital (MTD) with considerable interest, and have recently been involv...
The loss-carry back rules following an increase in earlier profits
The combined cases of Peter Lowe and Civic Environmental Systems Ltd v HMRC [2022] UKUT 84 (TCC) addressed three very di...
Embiricos: the scope of partial closure notices
The original Self-Assessment code was drafted almost 30 years ago and it might be said that its age is showing in places...
A new tax regime for qualifying asset holding companies
The UK has done much in recent years to build its reputation as a location for fund management.
The OTS launches a new review of tax simplification
The Office of Tax Simplification has just announced a new review to consider what tax simplification means....