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ANALYSIS
Cutting edge analysis on tax issues.
Complex statutory construction: the Court of Appeal’s approach in Tower One
Helen Coward
Cristy Ajediti
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
Trouble in store for the Sehgals
John Shallcross
John Shallcross (Blake Morgan) examines the counter-intuitive result in a mixed property SDLT decision.
Tax and the City for January 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review
Hotel La Tour
, recent developments affecting the taxation of global mobility and HMRC’s new compliance guidelines on imported hybrid mismatches.
Acting ‘as such’: the special legal regime after Northumbria Healthcare
Denis Edwards
A recent Supreme Court judgment is now the starting point for identifying when a special legal regime exists, writes Denis Edwards (Temple Tax Chambers).
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
Grandfathering
John Barnett
The Government’s approach to APR and BPR reform combines delay and
anti-forestalling in a way that risks serious unintended consequences,
writes John Barnett (CIOT).
Share reorganisations: new anti-avoidance rules explained
Peter Morley
Jamie Robson
The Autumn Budget 2025 tightens anti-avoidance rules for share
reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain
what tax professionals need to be aware of.
Tax and the private capital sector in 2026: three key issues
Elena Rowlands
Ian Zeider
Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) take stock
of current developments.
Direct and immediate links: the Supreme Court draws the line
Dr Michael Taylor
Dr Michael Taylor (PwC) reviews the Supreme Court’s judgment in
Hotel La Tour
.
That was the year that was 2025
Zoe Andrews
Nadia Hourihan
Zoe Andrews and Nadia Hourihan (Slaughter and May) offer a whirlwind
review of 2025’s tax highlights and curiosities.
Go to page
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458
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