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ANALYSIS
Cutting edge analysis on tax issues.
Parallel tracks
Phil Maggs
Phil Sneade
A common set of economic principles and methods underpins state aid,
competition and arm’s length analysis, write Phil Sneade and Phil Maggs
(Frontier Economics).
Private client review for June 2025
Sophie Dworetzsky
A long-awaited report on will reform and the recent announcement on
carried interest are among the developments covered in this month’s review
by Sophie Dworetzsky (Charles Russell Speechlys).
Competing views on the VAT exemption for medical care
Alex Spencer
Two recent cases demonstrate that the scope of the VAT exemption for health
and welfare is far from certain, writes Alex Spencer (Field Court Tax Chambers).
Carried interest tax reform: next steps
Bezhan Salehy
Damien Crossley
Damien Crossley and Bezhan Salehy (Macfarlanes) examine the
Government’s latest policy paper.
Tax and the City review for June 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
looks at the decisions in
Beard
and
Rettig
, as well as HMRC’s revised guidance
on unallowable purpose.
The Big, Beautiful Bill: one House down, one House to go
Andrew Solomon
As the Senate prepares to take up President Trump’s sweeping tax and spending
package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions
and what happens next.
Future focus: the potential reform of behavioural penalties
Thomas Wilkinson
Kate Garcia
Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on
the potential redesign or reform of penalties imposed for inaccuracies in tax
returns and failures to notify.
The Government amendments to domestic Permanent Establishment rules
James Anderson
Lorenza De Domenico
UK reforms to the permanent establishment rules and the Investment
Manager Exemption could reshape the tax treatment for non-resident
funds and UK investment managers, write James Anderson and Lorenza
De Domenico (Skadden).
Taxing rubbish: proposed overhaul of the landfill tax regime
Anastasia Nourescu
David Pickstone
David Pickstone and Anastasia Nourescu (Stewarts) consider the
Government’s proposed reform of the landfill tax regime and its impact
on industry.
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Mark Bevington (ADE Tax) highlights the areas where the new TP and UTPP
rules do not appear to work as intended.
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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
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
Requirement to file CIS nil returns
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker