European Tax

Transfer pricing experts are used to grappling with some tricky valuation questions when it comes to intellectual property rights.  After...

“I see the 1.5% is being removed!” was the subject line of a client e-mail received early last Thursday afternoon in light of HMRC’s...

The short version: it seems that it has, with effect from 1 January 2024, as a result of the Retained EU Law (Revocation and Reform) Bill...

Two years' ago I wrote a post entitled "Has the Chancellor really just announced a UK corporation tax rise of over 30%?" the gist of...

VAT has often held the answer to many of life's greatest mysteries. Why does my sandwich cost more if I eat in rather than eat out? Or if...

Following the Upper Tribunal's decision in BlackRock that third party covenants (i.e. not from the borrower itself) could not be taken...

With Article 7 of the OECD's Multilateral Instrument containing a Principal Purpose Test (or PPT) tax authorities, taxpayers and tax...

"We understand that some readers of this decision may find it surprising that an artificial series of transactions which, on the...

The draft Energy (Oil and Gas) Profits Levy Bill published on 21 June 2022 (the Bill) shows the difficulty, and danger, of using purpose...

The General Court released its decision in the UK's and ITV's appeals against the Commission's decision that the UK's CFC finance company...

A little over a year ago, I wrote a post called "The cautionary tale of Mr Bostan Khan". It was prompted by the Court of Appeal decision...

Net accounting has always thrown up some difficult questions for taxpayers and their advisers looking to claim a deduction for something...

A: Interest on a Kwik-Fit loan. The question "what's unallowable, but not disallowed?" is the riddle thrown up by the latest First-tier...

If you say it in a deep enough voice, "litigation on an epic scale" sounds like it may be the trailer for the latest summer blockbuster...

On 30 April 2021 the Court of Appeal handed down its unanimous judgment in Bostan Khan v HMRC. As tax cases go, it is neither the biggest...

For those who prefer to think in pictures, this chart from the OBR's 2018 report "Why have onshore CT receipts performed so well since...