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ANALYSIS
Cutting edge analysis on tax issues.
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
Navigating the protective assessment maze with Jeffries & Sons
Bryn Reynolds
Bryn Reynolds (Pinsent Masons) examines the recent
Jeffries
case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
Pillar Two one year on: what have we seen and where are we going?
Kara Heggs
Jisun Choi
Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Unless shadow advisers are effectively regulated and HMRC can act closer to
real time, we will soon once again be facing calls for regulation of the whole
profession, writes Ray McCann.
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax grouping (part 1): group relief and tax groupings
Maddy Potthast
Gavin Little
In the first in a series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) focus on the conditions for corporation tax loss
relief via group relief.
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
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430
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
HMRC issue coding notices Direction
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
MOST READ
Read all
Autumn Budget 2025: what tax measures can we expect?
HMRC manual changes: 17 October 2025
Management expenses: HMRC’s new nudge campaign
Tyler Security Ltd v HMRC
‘Partnership NICs’: the impact on the asset management sector