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Bloomsbury Professional Tax Insights

Parkes Andrew: Bloomsbury Professional
Tax Insight - Withholding Tax

Bloomsbury Professional Tax Insight - Withholding Tax

Alternative Dispute Resolution (ADR) has been an option for taxpayers and their advisers involved in enquiries or disputes with HMRC for a number of years, and it is now becoming increasingly popular as an alternative to taking a case to the First or Upper Tax Tribunal where there is a significant backlog in terms of cases being heard. The real attraction of ADR and a significant benefit to taxpayers, whether individuals or corporates, is that the process is completely confidential - in comparison to the potential embarrassment of tribunals where details are in the public domain. This book contains expert guidance on a variety of topics centred on Alternative Dispute Resolution, from how to complete the ADR form and guidance for the ADR meeting on the day, to what the Litigation Settlement Strategy is and an outline of the tribunal processes. It is a practical step by step guide with technical tax commentary, illustrated with real-life case studies and analysis of strategies employed in resolving these disputes. Readers will benefit from the practical experience of the author Jesminara Rahman, who has over 25 years experience in dealing with tax disputes and how to use ADR as a tool to reach a resolution with HMRC, and who had a leading role in implementing ADR within HMRC as a national service. Jesminara Rahman is the Director of Tax Resolute Ltd. Her experience includes 15 years as an HMRC Inspector of Taxes and Tax Dispute Resolution expert.

Alternative Dispute Resolution (ADR) has been an option for taxpayers and their advisers involved in enquiries or disputes with HMRC for a number of years, and it is now becoming increasingly popular as an alternative to taking a case to the First or Upper Tax Tribunal where there is a significant backlog in terms of cases being heard. The real attraction of ADR and a significant benefit to taxpayers, whether individuals or corporates, is that the process is completely confidential - in comparison to the potential embarrassment of tribunals where details are in the public domain.

This book contains expert guidance on a variety of topics centred on Alternative Dispute Resolution, from how to complete the ADR form and guidance for the ADR meeting on the day, to what the Litigation Settlement Strategy is and an outline of the tribunal processes.  It is a practical step by step guide with technical tax commentary, illustrated with real-life case studies and analysis of strategies employed in resolving these disputes. 

Readers will benefit from the practical experience of the author Jesminara Rahman, who has over 25 years experience in dealing with tax disputes and how to use ADR as a tool to reach a resolution with HMRC, and who had a leading role in implementing ADR within HMRC as a national service.

Jesminara Rahman is the Director of Tax Resolute Ltd. Her experience includes 15 years as an HMRC Inspector of Taxes and Tax Dispute Resolution expert.

Bloomsbury Professional Tax Insight - A Guide to Alternative Dispute Resolution in the UK

Now in its 7th Edition, Miller, Hardy and Ismail on Company Reorganisations (previously Taxation of Company Reorganisations), is an essential reference source for tax advisers that covers the basic rules of corporation tax and capital gains, reorganisations, share exchanges and other deemed reorganisations, reconstructions, mergers, demergers and branch incorporations, as well as cross-border transactions. A variety of topics are discussed, from the reduction of capital rules, and interaction with substantial shareholding exemption, to qualifying corporate bonds (QCBs), reconstruction reliefs, and UK and cross-border mergers. The new edition brings the commentary up-to-date with recent Finance Acts including new provisions relating to share exchanges involving non-UK incorporated close companies introduced in Finance (No.2) Act 2023; and relevant new guidance from HMRC. There is also a new chapter on the multinational top-up tax and domestic top-up tax provisions as these apply to reorganisations. A number of important new cases are also analysed, including the following: - Euromoney Institutional Investor PLC (FT): Anti-avoidance on exchange of shares - Gallaher (various including UT and CJEU): intra-group transactions and EU law - Kavanagh (FT): Holding shares on trust - Blackrock (UTT), Oxford Instruments (FTT), and Kwik Fit Group Ltd (UT): unallowable purpose test - Altrad Services (UT): disclosed avoidance scheme - M Group Holdings (FTT): substantial shareholding exemptions Pete Miller is the Head of Corporate Tax at Jerroms Miller, a specialist tax advisory formed by the merger of the corporate transaction tax team of Jerroms and The Miller Partnership (which Pete founded in 2011). George Hardy is a retired partner of Ernst &amp; Young, where he specialized in financial services. He is now researching a book on the philosophical foundations of AI . Fehzaan Ismail is a Partner in EY's International Tax and Transaction Services team and advises clients in the Financial Services sectors.

Taxation of Company Reorganisations is one of the leading commentaries in the UK on dealing with all aspects of reorganising of restructuring a company.

Readers will benefit from the practical expertise of the authors, led by Pete Miller of Jerroms Miller and George Hardy and Fehzaan Ismail both of Ernst and Young, gained in the course of over 50 years of practical experience dealing with corporate tax transactions for clients all sizes.

The book contains expert guidance on a variety of topics, from the reduction of capital rules, and interaction with substantial shareholding exemption, to qualifying corporate bonds (QCBs), reconstruction reliefs, and UK and cross-border mergers. The commentary includes analysis of key cases and is supported by a series of easy to follow diagrams and flowcharts to support key points. 

The new edition brings the commentary up to date with recent Finance Acts including new provisions relating to share exchanges involving non-UK incorporated close companies introduced in Finance (No. 2) Act 2023; and relevant new guidance from HMRC including the unallowable purpose rules. 

A number of important new cases are also discussed, including the following:

 - Euromoney Institutional Investor PLC (FT): Anti-avoidance on exchange of shares
 - Gallaher (various including UT and CJEU): intra-group transactions and EU law
 - Kavanagh (FT): Holding shares on trust 
 - Blackrock (UTT): deductability of interest on a intra-group loan
 - Oxford Instruments (FTT), and Kwik Fit Group Ltd (UT): unallowable purpose test
 - Altrad Services (UT): disclosed avoidance scheme
 - M Group Holdings (FTT): substantial shareholding exemptions

This title is included in both the Gold and Platinum Online Tax Services.

Miller, Hardy and Ismail on Company Reorganisations

Schriften zum Öffentlichen Recht

Die Besinnung auf Prinzipien im Recht und ihre konkrete Realisierung besitzen das Potential, die Akzeptanz von finanzpolitischen Belastungsentscheidungen zu befördern. An schillernden Begriffen wie dem Vorteilsprinzip, welches das Abgabenrecht mitprägt, scheiden sich die Geister. Wann liegt ein Vorteil vor und (wie) lässt er sich quantifizieren? Wer ist zu dessen Bestimmung berufen und wie entfaltet es seine Wirkung im Konkreten? Die Untersuchung leuchtet das Vorteilsprinzip am Beispiel der wiederkehrenden Straßenausbaubeiträge aus: Ausgehend von der Grundlegung im pr. KAG werden finanzverfassungsrechtliche Leitplanken und gleichheitsrechtliche Maßstäbe mit dem Vorteilsprinzip verzahnt. Im Mittelpunkt steht die Frage, unter welchen Voraussetzungen wiederkehrende Beiträge mit diesem vereinbar sind. Gezeigt wird, dass ein eng gefasster, gesetzlich konturierter Sondervorteil erforderlich ist; zu weit gefasste Abrechnungseinheiten und großzügige Typisierungen gefährden die Lastengleichheit.

Dargestellt am Beispiel wiederkehrender Straßenausbaubeiträge

Das abgabenrechtliche Vorteilsprinzip im Steuerstaat

Durkheim and Sociological Critique

The Domain of the Ideal

'You need this book.' Steven Bartlett, author of The Diary of a CEO New York Times bestseller The world is changing. It's time for a new financial playbook. In this must-have guide to optimizing your life for wealth, success and happiness, you'll learn: ¿ how to find and follow your talent ¿ what small steps you can take now that pay big returns later ¿ how to develop better financial habits Bursting with practical, game-changing advice from one of the world's most popular business school professors, The Algebra of Wealth is the practical guidebook you need to win today's wealth game. Today's workers have more opportunities and mobility than any previous generation. They also face unprecedented challenges, including inflation, labour and housing shortages, and climate volatility. Even the notion of 'retirement' is undergoing a profound rethink, as our lifespans extend and our relationship with work evolves. In this environment, the tried-and-true financial advice our parents followed no longer applies. In The Algebra of Wealth, Galloway lays bare the rules of financial success in today's economy. In characteristic unvarnished, no-BS style, he explains you what you need to know in order to improve your chances of achieving economic security no matter what.

A Simple Formula for Success

The Algebra of Wealth

Containing penetrating analysis of problem areas, as well as practical guidance, The Law of Limited Liability Partnerships comprehensively sets out the law of limited liability partnerships in England and Wales. The Sixth Edition has been brought completely up to date and includes: - New LLP case law on LLP agreements, expulsion, standing of former members to apply for the restoration of a dissolved LLP, the enforceability of pre-incorporation contracts, discrimination, appointment of receivers and disqualification - New case law on tax issues affecting LLPs including on the salaried member rules and capital allocation - An expanded chapter, written in conjunction with local contributors, outlining LLP structures in overseas jurisdictions including corporate entity LLPs in Dubai, Qatar, Malaysia, Singapore, India, Pakistan, Kazakhstan, Guernsey, Gibraltar and Mauritius and non-corporate LLPs in the US, Canada, Japan, Hong Kong, Ireland, Jersey, Belize, and the Cayman Islands For legal practitioners and other professionals advising on the incorporation of an LLP, and on any of the legal and taxation aspects of carrying on a business through the medium of an LLP, The Law of Limited Liability Partnerships is a 'must have' purchase. This title is included in Bloomsbury Professional's Partnerships online service.

Whittaker and Machell on the Law of Limited Liability Partnerships

This title is written to provide tax advisers with an understanding of the UK tax rules applicable to trusts resident in the UK or abroad, and the resultant tax liabilities of the trustees, settlors and beneficiaries, and opportunities for reducing those liabilities where possible. As well as background to trusts and trustees' powers and duties, the commentary deals with the main types of private trusts and the rules that apply to them . There are also important chapters on residence and domicile and foreign trusts, charitable trusts, and purpose and heritage trusts. A number of specialist areas such as protective and vulnerable persons trusts are also dealt with. This new edition covers the once-in-a-generation legislative changes taking effect from April 2025, concerning the removal of non-dom rules. These include: - Abolition of domicile as a relevant factor in determining liability to inheritance tax, capital gains tax and income tax; - Remittance basis of taxation removed for 2025/26 and later years, but previous untaxed amounts held overseas will be taxed when remitted; - Liability to tax for 2025/26 and later years will be based on residence - UK resident settlors of offshore trusts will be taxable on trust income/gains on an arising basis from 2025/26, as the "protected trust" regime which has applied since 2017 is removed; - Offshore trusts settled by a non-UK domiciled settlor will be within the scope of inheritance tax if the settlor is a "long term resident" (LTR) of the UK. - Change in CGT rate for trustees was announced in Budget - increased from 20% to 24%. - The introduction of caps on Agricultural Property Relief (APR) and Business Property Relief (BPR) A digital version of this title is available as part of our online tax resources.

Tax Advisers' Guide to Trusts

Adopting distinct and new perspectives to analyse VAT policy and practice, this book explores the key design challenges and opportunities faced by VAT jurisdictions in the 21st century.


 The book shows how the VAT, the world's most preferred form of consumption tax, has failed to live up to the expectations of its advocates since its earliest iterations about a century ago. It identifies and explains the gaps between VAT theory and practice, drawing on lessons from recent international experience. The book begins with an analysis of key design features of VAT systems, including concessions, registration thresholds and small business regimes. It goes on to explore more complex issues, such as the application of the tax to financial supplies, sharing economy transactions, and international cross-border sales, as well as the treatment of transactions and revenue within jurisdictions that operate under multiple-tiered systems of government.These issues represent challenges commonly encountered in VAT jurisdictions in modern economies. The work outlines innovative and realistic reform proposals for a VAT suitable for a 21st century economy that are grounded in economic principles and at the same time, practicable in terms of law, policy, and administration. It factors in, in particular, the political, technical, and administrative realities that policymakers in VAT jurisdictions must navigate when developing reform programmes.


 With guidance on VAT design and implementation for policymakers and law drafters, the book is also a valuable resource for academics, students, and practitioners interested in VAT policy and practice, and the interactions between tax law, policy and economic principles.

Design, Challenges, and Opportunities

Value Added Tax in the 21st Century

'Requirements for National Tax Regulations Aimed at Family Businesses Derived from the Prohibition of State Aid': Based on the prohibition of state aid under European law, the author of this paper derives requirements for national tax law regulations aimed at family businesses. He argues that family business-related differentiations in tax regulations are permissible under state aid law if they result from a permissible principle or objective inherent in the system. In this context, he takes a closer look at the impact of the ability-to-pay principle and individual system-inherent objectives, such as job protection and the prevention of abuse.

Vorgaben des Beihilfeverbots für nationale Steuerregelungen gerichtet auf Familienunternehmen

Imagine a world where the simple act of journeying down a country lane could entangle you in a web of legal intrigue, where the rights and wrongs of the road shaped not just travel, but the very fabric of Victorian society. This captivating volume, now restored for today's and future generations, invites readers into the fascinating crossroads of British legal history and everyday experience, illuminating how nineteenth-century nonfiction can still resonate with modern concerns. With wit and precision, it unpacks the labyrinth of road safety regulations and transportation law history that governed the bustling highways and byways of Victorian England-a time when the rules of the road were as fiercely debated as they are today.

Drawing on the rich context of the Charles Dickens era, this legal history book explores the evolving rights of the traveller, revealing the social tensions and legal dilemmas that accompanied the rise of new forms of transport. It offers a vivid portrait of the period, capturing the anxieties and aspirations of those navigating the shifting boundaries between personal freedom and public order. Whether you are a casual reader intrigued by the quirks of the past, a legal scholar seeking a reference for the development of traveller legal rights, or a law student searching for a resource that brings the complexities of Victorian travel law to life, this work will reward you with its lively prose and meticulous detail.

Unavailable for decades and now republished by Alpha Editions, this edition is not just a reprint-it's a collector's item and a cultural treasure. Its restoration preserves a key piece of the legal classics collection, offering fresh insight into the laws that once governed every journey, from bustling city streets to remote country paths. Rich in historical significance and sparkling with relevance, this volume stands as a testament to the enduring legacy of British legal thought and the timeless quest for justice on the open road.

The law of the road; or, wrongs and rights of a traveller

An expert guide to the rules of inheritance tax relief for business, farm, woodland and heritage property, and the only book on the market to cover all these reliefs in the same volume. Significant changes to Agricultural Property Relief (APR) and Business Property Relief (BPR) were announced in the 2024 Autumn Budget and further Government updates followed in 2025. This new edition covers all of these changes, including: - The 100% relief currently available on all qualifying assets without any limit on value will now only be available on the first £2.5m of assets (in total) with a rate of 50% for assets above this limit. - Changes to application of relief to transfers on death and in the seven years before death - and how these will not be transferable to the spouse. - BPR on shares quoted on a recognised stock exchange but treated as unquoted (such as AIM) will be 50% from this date and will not be able to benefit from 100% relief - Coverage of numerous important tax cases in this area. The book discusses everyday situations that are likely to be encountered in practice and provides guidance on compliance, along with tips for making tax savings for clients. It also contains numerous examples of pitfalls to avoid in this complex area of tax law.

Agricultural, Business and Heritage Property Relief

Elements in Chinese Economy and Governance

In contrast to the drastic shifts in China's political landscape and society since 2012, taxation may appear as a comparatively mundane topic receiving limited attention. However, the relative stability in China's taxation system underscores its delicate role in maintaining a balance in state-society relations. The Element embarks on an exploration of China's intricate taxation system in the contemporary era, illuminating its origins and the profound reverberations on state-society relations. It shows that China's reliance on indirect taxation stems from the legacies of transitioning from a planned economy to a market-driven one as well as elaborate fiscal bargaining between the central and local governments. This strategy inadvertently heightens Chinese citizens' sensitivity to direct taxation and engenders the tragedy of the commons, leading to rising government debts and collusion by local governments and businesses that results in land expropriation, labor disputes, and environmental degradation.

Taxation and Governance in Contemporary China

Bloomsbury Professional Tax Insight - Withholding Tax

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