Podcast: Tax News: October 2024

In this podcast, tax associate Alex Sim joins Zoe Andrews and Tanja Velling to discuss the Upper Tribunal’s decision in Muller on the interaction of certain provisions in the intangible fixed assets regime with the rules on the taxation of partnerships.  

Zoe and Tanja also discuss the CJEU’s decisions in the Apple and UK CFC rules State aid cases, the Supreme Court’s decision in Professional Game Match Officials Limited on employment status and the stamp duty land tax case Brindleyplace in which the First-tier Tribunal employed purposive construction in favour of the taxpayer.

The podcast also covers a change to HMRC’s governance framework for resolving tax disputes, HMRC’s new Guidelines for Compliance (GfC7) on transfer pricing, some recent UK corporate tax statistics and the signature of the multilateral convention on the “subject to tax rule”.