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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City for March 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including
Sintra Global
, tax adviser registration and HMRC’s large business compliance approach.
Mixed member partnerships: anti-avoidance rules
A back to basics guide from Lexis®+ UK Tax.
HMRC’s Digital Disclosure Service: insights from practice
Jan Kolasa
Ben Webster
Tom O’Reilly
Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
HMRC’s Customer Compliance Group explained
Amit Puri
Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.
BTR late than never: SDLT overpayment relief
Helen Coward
‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.
Headless chickens: Morrisons and the FTT’s supervisory jurisdiction
Jack Prytherch
Yousuf Chughtai
The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).
The VAT review for March 2026
Gary Barnett
Gary Barnett (Simmons & Simmons) reviews recent VAT developments, including the Upper Tribunal’s decision in Lycamobile and CJEU guidance on statutory payments.
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hartley Foster (Addington Chambers) examines the right to obtain information from public authorities such as HMRC, via the Freedom of Information Act 2000, and the restrictions on that right.
Gifting APR/BPR assets on death
Simon Douglas
Simon Douglas (5 Stone Buildings) considers the will-drafting consequences of the new £2.5m allowance and its transferability – and explains why traditional ‘100% relief’ clauses may now not always achieve the desired result.
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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
Read all
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