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ANALYSIS
Cutting edge analysis on tax issues.
Taxation of cryptoassets for businesses
Robert Langston
Robert Langston (Saffery Champness) considers new HMRC guidance that provides some clarification, although there are still areas that are left open.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Locke: Court of Appeal again quashes follower and accelerated payment notices
Geoff Lloyd
Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
Farewell fiscal prudence?
David Smith Economics expert
Spending pledges are being flung around like confetti in the election campaign but politicians are coy about the fact that they will ultimately lead to higher taxes, as David Smith reports.
Tax and the City review for November 2019
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) provide your monthly update on tax developments affecting the City.
How to handle tax on corporate reconstructions
Paul Townson
Chris Holmes
Paul Townson and Chris Holmes (BDO) consider some of the common corporate reorganisations and demergers that companies may undertake, and the key risks and issues with each type of transaction.
VAT on real estate: TOGCs and other hot topics
Michael Thomas KC
Michael Thomas (
Pump Court Tax Chambers)
highlights some areas of topical interest for VAT and real estate.
Aozora and legitimate expectation: a guide to nowhere?
Constantine Christofi
Robert Waterson
The Court of Appeal's recent decision appears to set a high bar for establishing an unlawful breach of a taxpayer’s legitimate expectation, write Robert Waterson and Constantine Christofi (RPC).
Is the arm’s length principle dead?
Gary Richards
Robert Hartley
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
The VAT review for November 2019
Gary Barnett
Bryn Reynolds
Bryn Reynolds and Gary Barnett (Simmons & Simmons) provide your monthly review of the VAT developments that matter.
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454
EDITOR'S PICK
Budget 2026: options for taxing wealth
Dom Rothbarth
1 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
2 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
3 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
4 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
5 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
6 /7
The new Securities Transfer Tax: business as usual?
Georgina West
7 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
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
NEWS
Read all
Tax Journal authors for August and September
Labour conference backs wealth and windfall taxes, as Burnham pledges national care service
Welsh rates of income tax: HMRC report
New VAT guidance on partnership details
Further Scottish visitor levy changes
CASES
Read all
Jumpman Gaming Ltd v HMRC
K Poznic v HMRC
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Other cases that caught our eye: 2 October 2026
Environmental Services Ltd v HMRC
IN BRIEF
Read all
Loans to participators: s 455
Modernising the taxation of distributions
HMRC’s new anti-avoidance information notice powers
Substantial
Modernising the taxation of distributions: why now?
MOST READ
Read all
Modernising the taxation of distributions: why now?
Sir J Griffin v HMRC
HMRC powers and the taxpayer relationship: when is enough, enough?
Environmental Services Ltd v HMRC
Minerva Research Labs Ltd v HMRC