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ANALYSIS
Cutting edge analysis on tax issues.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
International review for May 2025
Tim Sarson
US developments dominate the headlines in this month’s update by
Tim Sarson (KPMG).
The Court of Appeal’s real-world view on the exemption for insurance intermediary services
Dr Michael Taylor
Dr Michael Taylor (PwC) considers whether Henderson LJ’s judgment in
WTGIL could bring all sorts of intermediary services back within the scope of
the VAT insurance exemption.
Beyond the billions: how the 100 Group’s tax contribution reflects a broader corporate responsibility
David Gordon
The discussion about tax responsibility should go beyond the rate of tax
companies pay, writes David Gordon (100 Group Taxation Committee).
Lifecycle of a transaction: Tax protections and W&I
Matt Davies
Elizabeth Emerson
Matt Davies and Elizabeth Emerson (DLA Piper) consider core tax
protections in share purchase agreements, and how they are impacted by tax
warranty and indemnity insurance.
Certainty in uncertain times
Erica Rees
Jenny Doak
Jenny Doak and Erica Rees (Weil, Gotshal & Manges) consider some of the
practical considerations surrounding the proposed process for providing
advance tax certainty for major projects.
FA 2025 EOT rules and the impact on valuations
Ritchie Tout
The recent changes to the Employee Ownership Trust rules bring the regime
back to its intended purpose – and may impact many valuations, writes
Ritchie Tout (Azets).
VAT and the management of Special Investment Funds: the last six years
Alex Tostevin
Etienne Wong
The application of this VAT exemption remains both complex and uncertain,
writes Alex Tostevin (Greenberg Traurig) and Etienne Wong (Old Square
Tax Chambers).
The clock is ticking on President Trump’s Tax Bill
Andrew Solomon
Andrew Solomon (Sullivan & Cromwell) explains why President Trump’s
plans for ‘one big, beautiful Bill’ are heading for one big, ugly negotiation.
TP, DPT and UTPP: twists, turns and transformations
Benjamin Crompton
Sarah Bond
Sarah Bond and Benjamin Crompton (Freshfields) examine the draft
legislation that amends certain aspects of the rules on transfer pricing and the
diverted profits tax.
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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