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IPT
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BEPS
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ANALYSIS
Cutting edge analysis on tax issues.
Judicial review in tax disputes
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) set out the general principles and the
practical aspects of advancing a judicial review claim.
International review for February 2025
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes insight on the latest
developments from the US Administration and the European Community.
Helping vulnerable individuals: a guide for tax professionals
Dawn Register
Chris Holmes
How do you spot the signs, and what steps should you take? Chris Holmes and Dawn Register (BDO) provide a practical guide for tax advisers.
Transfer pricing: why returns are rarely risk-free
Phil Maggs
Phil Sneade
Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Tristan Thornton
Joseph Howard
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
Private client review for February 2025
Dominic Lawrance
Sophie Dworetzsky
Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).
Sonder Europe and serviced apartments: TOMS or no TOMS?
Damon Wright
Damon Wright (K3 Tax Advisory) questions the Upper Tribunal’s ruling on the VAT Tour Operators Margin Scheme.
If I could turn back time: encouragement for taxpayers seeking rectification
Arthur Wong
Ben Elliott
Ben Elliott and Arthur Wong (Pump Court Tax Chambers) explain why
there are grounds for optimism for taxpayers seeking to rely on rectification as
a potential means of resolving disputes with HMRC.
Mersey Docks: you’re my wonderwall
Yousuf Chughtai
Davinder Sahota
Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision
which shows how complex and large structures can be considered to function
as plant for capital allowances purposes, even where other premises-like
functions may exist.
Tax and the City review for February 2025
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent tax
developments that matter, including the ruling in ScottishPower and HMRC’s
draft guidance on the multinational top-up tax and domestic top-up tax.
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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
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
HMRC issue coding notices Direction
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘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?
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