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ANALYSIS
Cutting edge analysis on tax issues.
TP and UTPP in Finance Bill 2026: more complexity and uncertainty
Edward Buxton
David Haughey
Sarah Bond
The Finance Bill rules introduce further complexity to the earlier draft
provisions and place an unwelcome reliance on HMRC guidance, write
Sarah Bond, Edward Buxton and David Haughey (Freshfields).
Demystifying the Substantial Shareholdings Exemption
Jennifer Plummer
Jennifer Plummer (BDO) considers the requirements for this valuable relief
and outlines some of the complexities involved where corporate structures are
not straightforward.
International review for January 2026
Tim Sarson
This month, Tim Sarson (KPMG) reviews the Pillar Two Side-by-Side
package, the Japanese tax proposals and the French Budget, and considers
what to expect in the coming year.
TOMS, taxis and private hire vehicles
Damon Wright
Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.
A Budget for its times? The Scottish Budget 2026/27
Alan Barr
Isobel d'Inverno
Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).
A new service for tax certainty on major projects
Finn Halton
Gregory Price
HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).
Private client review for January 2026
Sophie Dworetzsky
In this month’s update, Sophie Dworetzsky (Lombard Odier) reports the late change to the IHT reforms, the sharp increase in transparency and compliance obligations and some of the latest court rulings that matter.
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
Jivaan Bennett
Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.
EOTs: are they still one of the best ways to sell your company to its employees?
Chris Barker
Matthew Emms
The Budget changes may have reduced the appeal of selling a company to an EOT but it remains a tax-efficient option, write Matthew Emms and Chris Barker (BDO).
The OECD’s Pillar Two side-by-side package
Lisa Shipley
Alison Lobb
Ed Wright
Alison Lobb, Lisa Shipley and Ed Wright (Deloitte) outline the Inclusive Framework’s much-awaited ‘side-by-side’ package.
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EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
New HMRC withholding tax guidance
Tax Journal's 2026 Budget coverage
Budget 2026: Sovereign immunity - a more considered reform
Budget 2026: the tax measures