7/10/2025 1:24:26 PM There’s only one POEM – but it’s not of the rhyming sort! By Zoe Andrews The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation....
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...
6/25/2025 3:53:29 PM UK Supreme Court in Dolphin Drilling decides that the meaning of “incidental” depends on statutory context By Zoe Andrews The Supreme Court in Dolphin Drilling dismissed the taxpayer’s appeal, agreeing with the Court of Appeal that the provision of...
4/15/2025 3:59:21 PM Court of Appeal in WTGIL case holds insurance intermediary provides a single exempt supply By Zoe Andrews Young drivers can get a specialised form of motor insurance if they have a device fitted to the car which records and transmits...
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...
12/10/2024 4:44:31 PM Impact of the US election: what does it mean for tax policy? By Tanja Velling Zoe Andrews In a special episode of Slaughter and May’s Tax News podcast, we asked Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP,...
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...
10/10/2024 3:21:43 PM HMRC’s “known position” on transfer pricing compliance By Zoe Andrews HMRC’s Transfer Pricing Guidelines for Compliance (GfC7) are promoted as “best practice approaches to transfer pricing to lower risk and...
7/18/2024 9:34:44 AM The capital test for investment management expenses is the same as for trading expenses: UK Supreme Court in Centrica Overseas Holdings Limited By Zoe Andrews To what extent are professional advisory fees associated with the disposal of a loss-making investment deductible as management expenses...
6/18/2024 8:04:44 AM Lessons learned from JTI and other recent unallowable purpose cases By Zoe Andrews The main lesson to be learned is that it all depends on the specific facts and how they are presented to the fact-finding tribunal! JTI...
6/6/2024 2:09:54 PM Good news for secondary debt markets in interest withholding tax case before UK Upper Tribunal By Zoe Andrews HMRC v Burlington Loan Management DAC is an important decision for the smooth running of secondary debt markets. It is also a helpful...
5/28/2024 11:22:46 AM Tax Disputes Podcast: France By Zoe Andrews I’m sad to say we have reached the end of our round the world Tax Disputes podcast series but we are going out in style with a trip to...
5/14/2024 11:10:50 AM Tax Disputes podcast - India By Zoe Andrews In the fourth episode of our round the world Tax Disputes podcast series, we take you to India for a conversation with Mukesh Butani,...
4/23/2024 10:18:37 AM Tax Disputes Podcast - Brazil By Zoe Andrews We have launched our round the world Tax Disputes podcast series with the first episode covering Brazil. I enjoyed the conversation with...
1/12/2024 11:38:56 AM Everyone's a winner - but some wins are more substantial than others: latest OECD assessment of the impact of the global minimum tax By Zoe Andrews The global minimum tax is now in effect in the UK for qualifying multinational groups for accounting periods beginning on or after 31...
9/27/2023 1:34:09 PM Where are you on Pillar Two? By Zoe Andrews Advisers and businesses would be wise not to hold out for finality and certainty before engaging with these highly complex and evolving...