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ANALYSIS
Cutting edge analysis on tax issues.
In conversation with... Ray McCann
Anthony Inglese
Ray McCann
Ray McCann, author of the recent loan charge review, talks to Anthony Inglese
about the moments that shaped his approach to tax for half a century.
The 2025 loan charge review and Government response: the final chapter?
David Pett
All but one of the loan charge review’s ‘hard’ recommendations have been
accepted. David Pett (Temple Tax Chambers) assesses both the review and
the Government’s response – and considers the implications for affected
taxpayers and the new settlement opportunity.
Saunders: new uncertainty for contractual employee incentive arrangements
Peter North
Rob Sharpe
Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal
ruling on the taxation of stock appreciation rights – a decision that introduces
fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.
The VAT review for December 2025
Katie Oliver
Gary Barnett
Katie Oliver and Gary Barnett (Simmons & Simmons) review recent
VAT developments on factoring, public bodies, input VAT evidence and
intermediaries’ recovery rights.
Risky business: the basics and use cases of tax insurance
Kate Pearson
Annabelle Trotter
Helen Coward
The tax insurance market has grown significantly. Helen Coward (Simmons &
Simmons) speaks with Annabelle Trotter and Kate Pearson (Howden) about
how it is now used across an increasingly broad range of transactions.
International review for December 2025
Tim Sarson
Tim Sarson (KPMG) reports key international developments, led by the OECD’s
long-awaited guidance on permanent establishments for remote workers,
alongside major updates from Brazil, Canada, the EU and the CBAM regime.
More of a stew than a smorgasbord?
Chris Sanger
The Chancellor managed to deliver a package that felt both familiar and, in
places, surprisingly bold, writes Chris Sanger (EY).
Budget 2025: Economics view: One and done… becomes two and done
Duncan Weldon
A year ago, the Chancellor, unveiling around 40bn of annual tax rises in her first Budget, was keen to emphasise that she would not be back asking for more. This was a one and done approach. The still new Government hoped for one painful...
Budget 2025: Curtailing TOMS
Etienne Wong
And the Chancellor said: And I will improve competition in our taxi industry by ending ride-hailing companies use of a discount scheme intended for coach tours In 35 years of practice, I have never heard the VAT Tour...
Budget 2025: Energy: the fiscal regime post-EPL
Paul Rogerson
No changes were announced in the Budget to the rates of ring fence corporation tax, supplementary charge to corporation tax or the energy profits levy (EPL). There was no announcement on any change to EPL and therefore this will remain in place until...
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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
Finance Bill 2026 published