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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for June 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
looks at the decisions in
Beard
and
Rettig
, as well as HMRC’s revised guidance
on unallowable purpose.
The Big, Beautiful Bill: one House down, one House to go
Andrew Solomon
As the Senate prepares to take up President Trump’s sweeping tax and spending
package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions
and what happens next.
Future focus: the potential reform of behavioural penalties
Thomas Wilkinson
Kate Garcia
Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on
the potential redesign or reform of penalties imposed for inaccuracies in tax
returns and failures to notify.
The Government amendments to domestic Permanent Establishment rules
James Anderson
Lorenza De Domenico
UK reforms to the permanent establishment rules and the Investment
Manager Exemption could reshape the tax treatment for non-resident
funds and UK investment managers, write James Anderson and Lorenza
De Domenico (Skadden).
Taxing rubbish: proposed overhaul of the landfill tax regime
Anastasia Nourescu
David Pickstone
David Pickstone and Anastasia Nourescu (Stewarts) consider the
Government’s proposed reform of the landfill tax regime and its impact
on industry.
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP
rules do not appear to work as intended.
Tribunal support for ADR: stick or carrot?
Ben Elliott
Peter Nias
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent
practice statement and other measures supporting the greater use of ADR.
The VAT review for June 2025
Gary Barnett
Joao Martinho
This month’s review by Joao Martinho and Gary Barnett (Simmons &
Simmons) covers the Court of Appeal decision in
Impact Contracting
Solutions
and two recent cases on the meaning of consideration.
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s
latest policy statements.
Improving HMRC’s approach to dispute resolution
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
Go to page
of
435
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for December
HMRC manual changes: 12 December 2025
Finance Bill 2026 published
HMRC revise position on VAT grouping and the Skandia judgment
HMRC explain TOMS changes
CASES
Read all
Cases of 2025
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
TSI Instruments and import VAT recovery
Tax Journal's 2025 Budget coverage
Executor of P Goudman-Peachey v HMRC