European Tax

There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...

Clashes between deeming provisions in a complex tax code inevitably give rise to tricky technical questions and, quite often, litigation....

Limited liability partnerships are bodies corporate with a legal personality separate from that of their members. But an LLP which...

Not far enough to let the taxpayer escape UK tax under the UK/South Africa Tax Treaty, according to the Supreme Court in Fowler v HMRC....