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ANALYSIS
Cutting edge analysis on tax issues.
Tax Update day: a flexible friend?
Chris Sanger
A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.
Tax Update 2026
A report by Lexis®+UK Tax
HFFX: the widening reach of miscellaneous income
Tom Margesson
Elena Rowlands
Ian Zeider
A low bar for ‘source’? Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) explain the Supreme Court’s decision in HFFX and its significance for LLP member remuneration.
The VAT review for July 2026
Gary Barnett
Karen Bannister
In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.
In conversation with… Rt Hon Sir Mel Stride MP
Anthony Inglese
Anthony Inglese CB talks to the Shadow Chancellor, Sir Mel Stride, about fiscal restraint, the lessons of the Truss Budget, HMRC accountability and the case for a simpler, flatter tax system.
The new carried interest regime: implications for non-residents working in the UK
Alex Ereira
Aron Joy
The carried interest reforms create substantial compliance burdens and may
expose internationally mobile investment managers to double taxation, write
Aron Joy and Alex Ereira (Weil, Gotshal & Manges).
Mandatory tax adviser registration: clearer, but not clear enough
Emma Rawson OBE
Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new
Mandatory Tax Adviser Registration Manual.
Loans to participators: where are we now?
Paul Townson
Chris Holmes
Paul Townson and Chris Holmes (BDO) examine the recent changes
which are making the loans to participators regime more onerous for close
companies and advisers.
Estoppel and abuse of process in VAT
Claire Logan
Claire Logan (Grant Thornton) explains why estoppel and abuse of process
are increasingly relevant in VAT disputes and how they can materially affect
how cases are argued and resolved.
International review for June 2026
Tim Sarson
Pillar Two filing, an AG opinion on the EU anti-abuse rule and Budget
measures in Australia and New Zealand are among the developments in this
month’s review, by Tim Sarson (KPMG).
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448
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC manual changes: 26 June 2026