ANALYSIS

Cutting edge analysis on tax issues.

Rob Sharpe

Thomas Peet

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

Penny Cogher

Penny Cogher (Irwin Mitchell) examines the extension of IHT to pension funds from April 2027, including the new concept of ‘notional pension property’, expanded liability for tax, and the significant practical and administrative challenges for PRs, schemes and beneficiaries.

Emma Rawson

Emma Rawson (ATT) reviews the MTD for Income Tax regulations, highlighting late legislative changes, complex entry and exit rules, quarterly reporting mechanics, and the wide-ranging exemption regime.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reviews recent developments including rejected calls to extend IHT payment deadlines, proposed expansion of the UTT regime to individuals and trusts, and practical issues arising from pensions, SDLT and trust changes.

Ros Martin

Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) consider the Court of Appeal’s purposive approach to the notional company fiction in Muller, HMRC’s consultation on extending the Uncertain Tax Treatment regime, and the proposed UK corporate re-domiciliation regime.

Liam McKay

Adam Craggs

Adam Craggs and Liam McKay (RPC) review recent decisions on costs for unreasonable behaviour, the use of AI in litigation and the scope of the FTT’s jurisdiction, as well as increased HMRC criminal investigations into advisers.

Gary Barnett

Karen Bannister

Karen Bannister and Gary Barnett (Simmons & Simmons) review recent decisions on VAT exemptions for securitisation vehicles and in-game currencies, the treatment of loyalty points, and the reduced rate for public EV charging.

Abigail McGregor

Jake Landman

Jake Landman and Abigail McGregor (Pinsent Masons) revisit the discretionary regime allowing HMRC to suspend penalties for careless inaccuracies, in light of recent Upper Tribunal guidance.