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ANALYSIS
Cutting edge analysis on tax issues.
Penalty suspension
Jake Landman
Abigail McGregor
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.
What is a Scottish taxpayer and what happens when they move during a tax year?
Chris Campbell
As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers.
In conversation with… Sir Sajid Javid
Sir Sajid Javid
Anthony Inglese
Former Chancellor Sir Sajid Javid talks to Anthony Inglese CB about his
journey from a childhood above the family shop to high office, and the realities
of tax policy in government.
International review for March 2026
Tim Sarson
Once again, the US dominates the international tax news cycle, reports
Tim Sarson (KPMG).
PE: don’t believe the hype
Nick Thornton
Is the UK’s domestic Permanent Establishment definition reform fair,
simple and supportive of growth, or is it, in reality, yet further complexity,
asks Nick Thornton (Fried Frank).
So much ‘noise’: HMRC’s evolving approach to corporate compliance
Vicky Topps
Karmjit Mader
HMRC’s increasing focus on upstream compliance and a more data-led, riskbased
approach marks a clear shift away from the traditional enquiry cycle,
as Vicky Topps and Karmjit Mader (KPMG) explain.
The new 40% first year allowance
Paul Farey
Paul Farey (AECOM) reviews the new rules and HMRC’s guidance.
Private client review for March 2026
Sophie Dworetzsky
From AI in court to IHT and judicial review, Sophie Dworetzsky
(Lombard Odier) reviews the latest developments.
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Henry Bennett-Gough
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in
Boston Consulting Group
and its implications for mixed member LLP structures.
How AI can help democratise tax administration
Stephen Daly
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
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453
EDITOR'S PICK
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
1 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
2 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
3 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
4 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
5 /7
The new Securities Transfer Tax: business as usual?
Georgina West
6 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
7 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
NEWS
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Tax receipts rise, but borrowing exceeds OBR forecast ahead of Budget
Construction industry scheme compliance
CIOT urges legislative change on pre-development costs
CIOT backs faster land remediation relief but warns on planning link
Only one in ten highest earners pay top tax rate, says CenTax
CASES
Read all
Environmental Services Ltd v HMRC
Sir J Griffin v HMRC
Minerva Research Labs Ltd v HMRC
Other cases that caught our eye: 25 September 2026
J Scheckter v HMRC
IN BRIEF
Read all
Substantial
Modernising the taxation of distributions
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
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Consultation tracker
J Scheckter v HMRC
The new taxpayer duty to correct inaccuracies: practical consequences for M&A transactions
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5
Redrawing the line: modernising the taxation of distributions