8/15/2025 8:18:04 AM Applying tax treaties to pensions payments: the First-tier Tribunal’s decision in Masters By Tanja Velling Where are your pension payments taxed if you retire abroad? The UK’s First-tier Tribunal (FTT) had to grapple with this question in...
8/6/2025 10:35:18 AM HMRC’s procedural blunder: How far does the UK Supreme Court’s decision in Zipvit go? By Tanja Velling Not as far as HMRC would appear to want it to. The First-tier Tribunal’s procedural decision in Motorplus is another example of somewhat...
8/1/2025 8:49:36 AM UK inheritance tax changes will add to administrative burden on pension schemes By Karen Mumgaard In October 2024, the UK Government announced as part of the budget that from 6 April 2027, “inherited pensions [will be brought] into...
7/1/2025 2:01:51 PM Section 899 compromise shifts international tax landscape By Zoe Andrews Tanja Velling The spectre of the section 899 “revenge” or “foreign investor” tax was still looming over us when we recorded a podcast with Arvind...
5/2/2025 2:19:03 PM Transfer pricing, permanent establishment and diverted profits tax reform – draft legislation By Alex Sim Gianni Prenol As we previously reported, on 28 April 2025 the UK government announced a technical consultation on draft legislation (the Draft...
4/28/2025 3:58:18 PM UK tax changes on the horizon By Tanja Velling How foolish I was for thinking that occasions such as an Autumn Budget or Spring Statement would no longer be followed by a “tax...
3/26/2025 5:24:21 PM UK Spring Statement 2025: No fiscal event, but some developments of interest By Tanja Velling The UK’s Spring Statement delivered on 26 March 2025 did not include further tax increases and the Chancellor stuck to her commitment to...
3/18/2025 9:45:11 AM Court of Appeal’s decision in Gunfleet Sands: a boost to the UK government’s infrastructure drive By Adam Merlander The Court of Appeal published their decision in Gunfleet Sands on 17 March 2025, upholding the taxpayers’ appeal on the availability of...
2/19/2025 1:10:04 PM Ramsay reined in? Does the dissent in the UK Supreme Court case of Royal Bank of Canada signal changes to statutory construction principles? By Kasim Mehmood What do tax lawyers talk about at lunch? In my case, it’s been the UK Supreme Court's majority decision (4:1) in Royal Bank of Canada. My...
2/13/2025 4:28:15 PM A question of interpretation: the UK Supreme Court’s decision in Royal Bank of Canada By Zoe Andrews All has ended well for the Royal Bank of Canada (RBC) following the Supreme Court’s majority decision (4:1) that the UK does not have...
1/30/2025 9:52:45 AM Joint ventures and the top-up taxes: does HMRC's draft guidance bring clarity? By Stephanie Mullins HMRC published supplementary draft guidance on the Multinational Top-up Tax (MTT) and Domestic Top-up Tax (DTT) covering, among other...
1/17/2025 4:58:31 PM Can you get tax deductions for payments in lieu of penalties? The UK Court of Appeal says YES! By Tanja Velling UK regulators had investigated failings by several energy providers. The investigations were settled with the imposition of nominal £1...
12/18/2024 10:36:25 AM Balancing growth and taxes: the UK government's corporate tax roadmap By Tanja Velling The announcement of a Spring Statement (rather than another Budget) on 26 March 2025 chimes with the promise of “predictability,...
12/11/2024 11:32:47 AM Purposive interpretation by the UK Supreme Court in Cobalt Data Centre By Kasim Mehmood In what appears to be a case confined to the application of the now expired capital allowances regime in respect of “enterprise zones”,...
12/5/2024 1:27:31 PM Partial enquiry notices – thumbs up or thumbs down? By Zoe Andrews “Mind the pennies and the pounds will look after themselves” is something my grandmother often said to me in days when pocket money was...
11/25/2024 10:13:16 AM How do you value an APA after the Court of Appeal's decision in Refinitiv? By Mike Lane Transfer pricing experts are used to grappling with some tricky valuation questions when it comes to intellectual property rights. After...