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ANALYSIS
Cutting edge analysis on tax issues.
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Iarlaith McCarthy-Hann
Rob Sharpe
Rob Sharpe and Iarlaith McCarthy-Hann (Cleary Gottlieb) examine the Finance Bill provisions.
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.
An increasingly tough stance on behavioural penalties
Sophie Rhind
Elvira Colomer Fatjo
Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.
Isle of Wight NHS Trust: will exempting doctors leave posts unfilled?
Adam Marshall
Adam Marshall (Berthold Bauer VAT Consultants) assesses the FTT’s rejection of HMRC’s narrow reading of Item 5 – and considers the consequences for healthcare staffing models.
COP 9 and serious tax fraud: HMRC’s tougher approach
Simon York CBE
HMRC are adopting a tougher stance with those who continue to deliberately
mislead or refuse to cooperate, despite being in the COP 9/CDF process,
writes Simon York CBE (Deloitte).
TP and UTPP in Finance Bill 2026: more complexity and uncertainty
Edward Buxton
David Haughey
Sarah Bond
The Finance Bill rules introduce further complexity to the earlier draft
provisions and place an unwelcome reliance on HMRC guidance, write
Sarah Bond, Edward Buxton and David Haughey (Freshfields).
Demystifying the Substantial Shareholdings Exemption
Jennifer Plummer
Jennifer Plummer (BDO) considers the requirements for this valuable relief
and outlines some of the complexities involved where corporate structures are
not straightforward.
International review for January 2026
Tim Sarson
This month, Tim Sarson (KPMG) reviews the Pillar Two Side-by-Side
package, the Japanese tax proposals and the French Budget, and considers
what to expect in the coming year.
TOMS, taxis and private hire vehicles
Damon Wright
Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.
A Budget for its times? The Scottish Budget 2026/27
Alan Barr
Isobel d'Inverno
Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).
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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
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