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ANALYSIS

Cutting edge analysis on tax issues.

In what is expected to be a very significant shake up of the distributions tax rules, the Government has decided to implement (in one form or another) the seven proposals it set out in its consultation on modernising the taxation of distribution and...
This years Budget has the feel of robbing Peter to pay Paul (though sadly not our editor). For this practitioner, HMRCs Corporate Tax Simplification for Business Investment consultation raises further concerns, while AI...
The 2026 Budget provided important detail on how HMRC intends to progress the standardisation of company tax returns, while a new Modernising the Administration of Corporation Tax call for evidence places those changes within a much broader,...
The UK currently treats sovereign immunity as a principle of international law under which one sovereign state cannot impose its laws, including its tax laws, on another sovereign. Accordingly, all UK source income and gains received by a sovereign...
The biggest news for the real estate sector was a change to the tax treatment of overseas sovereign investors from January 2029. That was a surprise. If an idea is dismissed, the real estate industry can be forgiven for thinking that it would not be...
Four stamp taxes measures for Finance Bill 2027 buried in the OOTLAR (paras 1.611.64) are: the removal of SDLT on rent under assured tenancies and the requirement to file a return solely because rent is payable, with retrospective effect from...
The Chancellors decision to expand and rename the Company Share Option Plan (CSOP) as EMI2 will be welcomed by businesses seeking to attract and retain talent. The Government positions EMI2 as an option for growing companies that...
This was a very vanilla Budget (a good thing) and banks have taken the biggest hit. There is also a nod towards chipping away at the gap between tax on work vs tax on assets. Passive rental income is being squeezed which is administratively...
Many pensions changes have already been trailed, including the new pension tax allowance for pensioners. This applies to pensioners whose income is at or under the value of the full new state pension so they will not have to pay income tax because of...
VAT rarely grabs the Budget headlines, but there is an obvious candidate for the front pages with the extension of the temporary zero VAT rate for domestic and qualifying electricity until July 2027. In his Budget speech, the chancellor continually...
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