ANALYSIS

Cutting edge analysis on tax issues.

Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans to widen the UTT regime and the practical implications for taxpayers.

Nigel Doran

Lika Jatoeva

Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated guidance on deferred remuneration for internationally mobile employees and consider the resulting risks of double taxation and NICs mismatches.

Liesl Fichardt

Emily Au

Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in tax disputes and the implications for transparency, fairness and taxpayer challenges.

James Camidge

Abhay Srivastava

Abhay Srivastava and James Camidge (Weightmans) explain what the UK CBAM is and how to prepare for the compliance challenge ahead.

Tim Sarson

Responding to unexpected and rapidly emerging events is currently the defining theme of international tax policy, writes Tim Sarson (KPMG).

Thomas Peet

Rob Sharpe

Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals to require close companies to report all transactions with participators, assessing the likely compliance burden and unintended impact beyond small businesses, particularly for private capital structures.

Penny Cogher

Penny Cogher (Irwin Mitchell) examines the extension of IHT to pension funds from April 2027, including the new concept of ‘notional pension property’, expanded liability for tax, and the significant practical and administrative challenges for PRs, schemes and beneficiaries.

Emma Rawson

Emma Rawson (ATT) reviews the MTD for Income Tax regulations, highlighting late legislative changes, complex entry and exit rules, quarterly reporting mechanics, and the wide-ranging exemption regime.

Sophie Dworetzsky

Sophie Dworetzsky (Lombard Odier) reviews recent developments including rejected calls to extend IHT payment deadlines, proposed expansion of the UTT regime to individuals and trusts, and practical issues arising from pensions, SDLT and trust changes.

Ros Martin

Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.

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