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ANALYSIS
Cutting edge analysis on tax issues.
Getting closure in transfer pricing and DPT enquiries
Tom Gilliver
Tom Gilliver (Slaughter and May) considers the procedural challenges that arise from the interaction between the transfer pricing and diverted profits tax rules.
HMRC’s trust registration service: changes for employee trusts
Liz Hunter
Graeme Whitfield
Liz Hunter and Graeme Whitfield (KPMG) examine the new registration requirements for EBTs and EOTs.
Public interest business protection tax
Colin Smith
A new tax is designed to deter owners of energy supply businesses from removing assets on which the business’s survival depends, writes Colin Smith (PwC).
Urenco: plant and machinery allowances
Will Scott
Susie Brain
Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
The VAT review for March 2022
Jo Crookshank
Gary Barnett
HMRC’s revised guidance on early termination payments and several advocate general opinions are among the recent VAT developments reviewed by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Asset holding company regime: the ownership condition
Rhiannon Kinghall Were
Damien Crossley
Damien Crossley and Rhiannon Kinghall Were (Macfarlanes) examine the most complex of the conditions contained in the new regime.
VAT on compensation payments: clarity at last?
Katie Raine
Richard Woolich
Although some uncertainty remains, from 1 April there will be fewer situations where HMRC accepts that early termination and compensation payments are not subject to VAT, write Katie Raine and Richard Woolich (DLA Piper).
Transfer pricing: new guidance on hard to value intangibles
Vladimir Milic
Anton Hume
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
International review for February 2022
Tim Sarson
Pillar one, UAE’s new federal corporate tax regime, and the Indian government’s Union Budget are among the recent developments examined
by Tim Sarson (KPMG).
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Tax Journal authors for March
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
J Hosking v HMRC