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ANALYSIS
Cutting edge analysis on tax issues.
Management expenses: HMRC’s new nudge campaign
Constantine Christofi
Anna Lucey
HMRC’s nudge campaign signals a broader challenge to deductibility under
CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).
Budget 2025: the view from the 100 Group Tax Committee
Dominic Mathon
Dominic Mathon (100 Group Tax Committee) reiterates the urgent need for
tax reform to encourage UK investment and boost economic growth.
SDLT and residential properties: mix up with a fix up
Max Schofield
The case of
Mudan
has likely closed the door on claims that unsound
properties qualify for non-residential rates of SDLT, writes Max Schofield
(Devereux Chambers).
Contentious tax quarterly: Autumn 2025
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a review of the recent
procedural decisions that offer important guidance for taxpayers and
practitioners.
VAT on locum medical practitioners: a ‘fractious’ case
Rachel Jones
Steven Porter
The supply of locum medical practitioners could be VAT exempt.
Steven Porter and Rachel Jones (Addleshaw Goddard) discuss the
tribunal’s approach.
Medpro: better late than never
Stacey Cranmore
Medpro
frees the tribunal from Martland’s fetters, writes Stacey Cranmore
(Pump Court Tax Chambers).
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
Private client review for October 2025
Sophie Dworetzsky
In this month’s report, Sophie Dworetzsky (Lombard Odier) reports growing
concerns over draft tax reforms, and the latest court rulings on retrospective
tax status and trustee replacement.
OBBBA: one big beautiful guide for non-US tax professionals
Paul McColgan
Jason Groves
Mark Saunderson
Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out
some recommendations for UK professionals advising businesses with large
US operations.
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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
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
Requirement to file CIS nil returns
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
CooperVision Lens Care Ltd v HMRC
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Countrywide Partners Ltd v HMRC
Charge My Street Ltd v HMRC
Tax agent registration and financial services