Macfarlanes

Taxpayers and advisers make widespread use of HMRC’s guidance when interpreting the tax legislation.  However, the guidance is often of...

Following Labour’s landslide general election victory, Sir Keir Starmer has appointed a new set of Treasury ministers, led by the...

In this article in the Tax Journal, we comment on how a “careless” mistake can have serious consequences in relation to your tax...

In this article in the Tax Journal, we comment on the recent FTT case, GCH Corporation, which highlighted the potential for tax avoidance...

In this article for Tax Journal, we comment on the Government's latest announcement in relation to carried interest and the next steps....

In this article for Tax Journal, Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjó take a practical look at UK interest withholding...

In Tax Journal, Sarah Ling and Ellen Wildig explore the wider impact for family-controlled businesses of the upcoming reforms to business...

ATAD 3, also known as the Unshell directive, is an EU measure that will impose minimum substance requirements for holding companies. This...

In a Tax Journal article, Sophie Rhind and Victoria Braid comment on the strict approach taken by the FTT to HMRC’s failure to comply...

In a Tax Journal article, Bezhan Salehy and Deep Shah review the Government’s extensive package of proposals that touch most areas of the...

In a Tax Journal article, Bezhan Salehy and Sarah Ling examine whether the Pillar Two undertaxed profits rule is susceptible to challenge...

In a recent Tax Journal article, Ceinwen Rees and George Apps compare the UK’s carried interest regime to European models. Over the past...

Despite attempts to coordinate implementation of the OECD’s Pillar Two project to introduce a minimum tax to a global schedule, countries...

Intra-group transfers of intangible fixed assets (IFAs) to or from LLPs are increasingly common as precursors to M&A transactions or...

In a recent Tax Journal article, Sophie Rhind and Victoria Braid discuss the circumstances in which taxpayers can apply for the...

Following the Supreme Court’s decision in Tooth, questions remained as to the type of knowledge a taxpayer must have when it comes to...