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ANALYSIS
Cutting edge analysis on tax issues.
Legislation day 2025: Private client perspective
Helen McGhee
Tweaks rather than reversals.
Giving advice in uncertain times
Jeremy Mindell
Ongoing speculation over tax changes presents significant challenges for
delivering reliable advice, writes Jeremy Mindell (Primondell).
Close encounters with close companies (part 1): definitions and concepts
Ross McGregor
Hannah Manning
In the first of two articles examining the close companies rules, Hannah
Manning and Ross McGregor (Travers Smith) explain why it should not be
assumed that a company is not close without looking carefully at the relevant
legislation.
Carry on paying on account (or risk paying more)
Frankie Beetham
Ceinwen Rees
The newly reformed tax on carried interest will subject carried interest to the
payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland
& Ellis) set out some of the key practical considerations.
BGC Services: lacking determination
Matthew Greene
Guy Bud
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision
which stresses the need for accountability and transparency from HMRC
when issuing determinations.
Private client review for July 2025
Sophie Dworetzsky
This month’s update, by Sophie Dworetzsky (Charles Russell Speechlys).
VAT assessment time limits: an affront to legal certainty
Fabian Barth
Fabian Barth (Alvarez & Marsal) examines the distinction between when an
assessment is ‘made’ and ‘notified’.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
It’s Consultation, Jim – but not as we know it...
Chris Sanger
At first glance, the Government’s revised approach to tax policy making retains
much of the existing framework. There is, however, a significant change on the
commitment to consultation, writes Chris Sanger (EY).
OBBBA: permanent tax cuts and international adjustments
Andrew Solomon
Aharon Friedman
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) report on an
action-packed seven days in Washington.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC suggest SDLT payments may trigger adviser registration rules
NIC (Employer Pensions Contributions) Act receives royal assent
CIOT raises concerns over large business compliance burden
Commonwealth Games income tax regulations
CIOT calls for modernisation of treaty clearance process
CASES
Read all
Professional Game Match Officials Ltd v HMRC
M Parker v HMRC
T Kwok v HMRC
Other cases that caught our eye: 8 May 2026
HMRC v Burlington Loan Management DAC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Project Snowball
Transfer pricing changes: foreign exchange
HMRC issue Spotlight 63a on hybrid partnership property schemes
One minute with... Jeff Soar
Protected foreign source income: limits exposed