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ANALYSIS
Cutting edge analysis on tax issues.
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines recent Government
proposals which, he says, leave little doubt that tax avoidance, like tax evasion,
is to be regarded as a criminal activity.
Tariffs: a history of American protectionism
Duncan Weldon
President Trump’s approach to tariffs fits within a longer history of American
protectionism, writes economist Duncan Weldon, but was that approach ever
successful?
Lifecycle of a transaction: transfer pricing considerations
Uwe Zoellner
Rachit Agarwal
Monia Volpato
Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set
out the transfer pricing aspects that should be considered during the
acquisition process.
The VAT review for May 2025
Jo Crookshank
Gary Barnett
VAT developments concerning transfer pricing adjustments, tripartite
arrangements and the Tour Operators Margin Scheme are examined in this
month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
Oliver Twentyman
Many advisers appear to be adopting a contrived and narrow interpretation of
the word ‘preferential’ in an attempt to provide commercial protection to EIS
investors on a winding-up, warns Oliver Twentyman (Azets).
Capital allowances: uncertainty over design costs resolved by Court of Appeal
Paul Farey
Paul Farey (AECOM) assesses the impact of the Court of Appeal’s judgment
in
Gunfleet Sands
.
Challenging HMRC’s debt management actions: lessons from Local Fuel
Daniel Williams
Michelle Sloane
A recent High Court decision provides valuable guidance for taxpayers
seeking to challenge enforcement action taken by HMRC’s Debt Management
team, write Michelle Sloane and Daniel Williams (RPC).
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
International review for April 2025
Tim Sarson
Key policy developments in the US and an AG opinion on VAT on transfer
pricing are among the topics examined this month by Tim Sarson (KPMG).
HMRC’s revised R&D guidance: the end of a long and winding road?
James Dudbridge
HMRC’s updated guidance marks the end of a long and winding road for
R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).
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435
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