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ANALYSIS
Cutting edge analysis on tax issues.
HMRC enquiries and data interrogation
Tony Monger
In every enquiry into a business, HMRC will seek to subject the accounting records to data interrogation. Tony Monger (Mazars) explains what HMRC is looking for.
Is the DST compatible with the UK’s international obligations?
Rupert Shiers
Jonathan T Stoel
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
International review for October 2019
Tim Sarson
Tim Sarson (KPMG) assesses the latest developments that matter in the
international tax arena.
Revised Brexit deal: changes and risks
Richard Asquith
What are the tax and customs implications of new Withdrawal Agreement and non-binding post-Brexit Political Declaration? Richard Asquith (Avalara) reviews.
VAT domestic reverse charge for construction services: where are we now?
Richard Dalton
The DRC is delayed but not abandoned. Richard Dalton (BDO) examines where things stand and what steps should be taken before its implementation.
Off-payroll working in the private sector: preparing for April 2020
Richard Johnson
David Smith
David Smith and Richard Johnson (DLA Piper) explain the detail of the changes set out in the draft legislation and the responses to the policy paper and consultation document.
How to choose your holding company location
Sara Luder
Charles Osborne
Sara Luder and Charles Osborne (Slaughter and May) examine the tax issues when choosing the location of a holding company.
Cliff edge: the meaning of ‘deliberate’
Sam Brodsky
Constantine Christofi
A recent tribunal decision erodes the behavioural distinction between ‘careless’ and ‘deliberate behaviour’, write Constantine Christofi (RPC) and Sam Brodsky (Gray’s Inn Tax Chambers).
The FTT’s recent approach to transfers of assets abroad
Rory Mullan
Rory Mullan (
Old Square Tax Chambers) examines two
cases that demonstrate the importance of establishing the
fundamental requirements of the TOAA code before a
charge can be imposed.
Private client review for October 2019
Andrew Goldstone
Stuart Adams
Andrew Goldstone and Stuart Adams (Mishcon de Reya) review the latest tax developments affecting private clients.
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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