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ANALYSIS
Cutting edge analysis on tax issues.
Finance Bill 2021: financial institution notices
Elena Rowlands
Ian Zeider
Despite criticism, financial institution notices look set to be introduced.
Elena Rowlands and Ian Zeider (Travers Smith) explore what this could
mean.
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
Why constructive ambiguity is sometimes the best policy
Jeremy Mindell
Jeremy Mindell (Primondell) believes that judicial interpretation of existing
legislation is preferable to a wholesale codification of the law that would
become outdated and easy to manipulate.
Capital allowances: s 198 elections
Sean Alexander
Steve Watts
Steve Watts and Sean Alexander (BDO) provide a practical guide to a
common practice for most commercial property transactions.
International review for April 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
The taxation of receivables finance transactions
Matthew Mortimer
Emma Noehrbass
Matthew Mortimer and Emma Noehrbass (Mayer Brown) consider some
important tax treatments that can apply to receivables finance transactions.
Conflicts in the tax code: two case studies
Edward Milliner
A recent case and an old conundrum provide neat illustrations of the problems that arise when statutory provisions come into conflict, as Edward Milliner (Slaughter and May) reports.
Wellcome Trust and the reverse charge
Etienne Wong
There are always corners hidden in the world of VAT that bear illumination,
writes Etienne Wong (Old Square Tax Chambers).
Stamp duty on insurance linked securities
Claire Miles
The government is taking a timely look at the stamp duty treatment of insurance linked securities. Claire Miles (Willkie Farr & Gallagher) considers what this means for the UK insurance market.
Private client review for April 2021
Edward Reed
Sam Epstein
Edward Reed and Sam Epstein (Macfarlanes) provide this month’s review of private client developments that matter.
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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
The new taxpayer duty to correct inaccuracies: practical consequences for M&A transactions