When the UK Supreme Court ruled in favour of HM Revenue and Customs (HMRC) in the Tower MCashback decision in May concerning capital allowances, many tax practitioners lamented what the Court seemed to be saying about the tax avoidance arguments that HMRC may advance during a hearing. The decision comes at a time when HMRC is entering into more enquiries and disputes with corporate taxpayers. Erin Kelechava investigates whether the case is yet another sign of a new era defined by more contentious relationships between Revenue and taxpayers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The US itself was the biggest loser of tax revenue to American multinationals’ profit shifting, the Tax Justice Network reported; in other news, firms made key tax hires
As multinationals embed tax technology into their TP functions, a new breed of systems – built on multi-model databases – is quietly transforming intercompany pricing logic
Clients are facing increased TP audit scrutiny in Hungary. DLA Piper Hungary is therefore using AI and advanced analytics to augment its advice, the firm’s head of TP says
As World Tax unveils its much-anticipated rankings for 2026, we focus on standout performances by PwC, KPMG and Deloitte across the Asia-Pacific region
The partnership model was looking antiquated even before the UK chancellor’s expected tax raid on LLPs was revealed. An additional tax burden may finally kill it off
The US’s GILTI regime will not be forced upon American multinationals in foreign jurisdictions, Bloomberg has reported; in other news, Ropes & Gray hired two tax partners from Linklaters