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ANALYSIS
Cutting edge analysis on tax issues.
Bryan Robson: when image and IR35 don’t mix
David Harmer
A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).
EIS disqualifying arrangements: jumping through the Hoopla
Tom Wilde
Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.
Private client review for March 2025
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.
Criminal offences and prosecutions for tax fraud
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) provide a back to basics guide.
APR and BPR reform: time to make hay while the sun shines?
Emma Haley
Hayden Bailey
After a wait of four months for more detail on the changes, what does
the consultation document now tell us? While there are some helpful
clarifications, not all of the concerns are addressed, write Hayden Bailey
and Emma Haley (Boodle Hatfield).
Initiative and the tax tribunal: a higher calling?
Bridget Winters
Calum Young
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Suboptimal access: HMRC and data requests
Robert Waterson
Lucy Collins
Robert Waterson and Lucy Collins (Eversheds Sutherland) examine a recent
High Court ruling that could encourage individuals to challenge HMRC if
they feel their personal data rights are being infringed.
Tax insurance: taxation of proceeds and gross-up
Laura Foley
Tom Cartwright
The taxation of insurance proceeds is relevant for sizing a policy limit.
Laura Foley and Tom Cartwright (Certa Insurance) consider various
practical scenarios and implications.
Tax and the City review for March 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
RBC: from the island of literal interpretation to the continental shelf
Kyle Rainsford
Victoria Hine
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Go to page
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430
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
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
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
Partnership NICs: experts warn of danger to LLP model
HMRC manual changes: 31 October 2025
Mandatory director identity verification brought into force
Single supervisor for anti-money laundering
HMRC to raise awareness of MTD
CASES
Read all
Illuminate Skin Clinics Ltd v HMRC
Eurocent (Buckingham) Ltd v HMRC
Tyler Security Ltd v HMRC
Other cases that caught our eye: 31 October 2025
Lands Luo Ltd v HMRC
IN BRIEF
Read all
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
Taking cover
MOST READ
Read all
Autumn Budget 2025: what tax measures can we expect?
HMRC manual changes: 17 October 2025
Management expenses: HMRC’s new nudge campaign
Tyler Security Ltd v HMRC
‘Partnership NICs’: the impact on the asset management sector