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ANALYSIS
Cutting edge analysis on tax issues.
Jersey’s economic substance for partnerships rules
Rupert Lee
New legislation brings certain partnerships within the scope of Jersey’s economic substance regime. Rupert Lee (Deloitte Jersey) reports.
Legal professional privilege in a tax context
Matthew Greene
Ian Hyde
Ian Hyde and Matthew Greene (Osborne Clarke) explain the basics of legal professional privilege and consider related practical issues in a tax context.
Murphy: earnings as profits and settlement payments
Darren Oswick
Matthew Norris
Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.
Basis period reform: a simplification with complications
Frances Edwards
Chris Holmes
Chris Holmes and Frances Edwards (BDO) summarise the existing basis
period rules and examine how things will change under the new proposals.
Tax and the City review for September 2021
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
KSM Henryk Zeman: FTT and legitimate expectation revisited
Clara Boyd
Catherine Robins
The
KSM
decision offers some glimmers of hope to those who think the FTT
should have jurisdiction to consider incidental public law issues, write
Clara Boyd and Catherine Robins (Pinsent Masons).
The VAT payments exemption: a moving Target
Richard Iferenta
Anthony Harb
A recent Court of Appeal judgment has narrowed the VAT payments
exemption. Richard Iferenta and Anthony Harb (KPMG) assess the impact
and call on the government to widen the scope of the UK’s exemption for the
post-Brexit world.
The FII group litigation: the end of the beginning or the beginning of the end?
Cristiana Bulbuc
Lee Ellis
The Supreme Court has handed down its third judgment in the long-running
FII GLO
case. Lee Ellis and Cristiana Bulbuc (Stewarts) consider how we got here and what this means for taxpayers with unresolved issues concerning overseas dividend taxation.
The UK asset holding company regime: a quacking idea!
James McCredie
James McCredie (Macfarlanes) reviews a hugely welcome new regime, but
explains there are still some ‘shoot in foot’ opportunities that it is to be hoped
the government and HMRC will resist.
Taxation of REITs: ringing in the changes
Phil Nicklin
Phil Nicklin (CMS Cameron McKenna Nabarro Olswang) examines the proposed changes introduced by the draft Finance Bill 2021/22 to make the UK REIT regime more attractive.
Go to page
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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
Read all
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: why now?
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
Read all
J Scheckter v HMRC
Consultation tracker
Redrawing the line: modernising the taxation of distributions
Sir J Griffin v HMRC
Minerva Research Labs Ltd v HMRC