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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for July 2025
Zoe Andrews
Mike Lane
Osmond, Eastern Power Networks
and HMRC’s guidance on their new
unilateral APA process are among the developments in this month’s review
by Mike Lane and Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Summer 2025
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) review some notable rulings on a
range of procedural issues, as well as recent changes to the tribunal rules.
The trials and tribulations of interest withholding tax
Rebecca Rose
Bezhan Salehy
Elvira Colomer Fatjo
Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes)
take a practical look at UK interest withholding tax, highlighting common
compliance pitfalls, HMRC’s approach and emerging complexities.
Beard: dividends of a capital nature
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) explains why form matters.
Keeping the receipts: HMRC’s burden in company insolvencies
Liesl Fichardt
Emily Au
HMRC’s preferential ranking brings into sharp focus their requirements to
evidence and substantiate their claims in an insolvency, as Liesl Fichardt and
Emily Au (Quinn Emanuel) explain.
The VAT review for July 2025
Jo Crookshank
Gary Barnett
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers recent decisions on the single/multiple supply rule and the
VAT finance intermediation exemption, as well as HMRC’s change of policy on
pension scheme costs.
Avoiding mistakes and costs when deregistering from VAT
Rob Janering
If not planned properly, deregistering for VAT can lead to significant
administrative and cost burdens. Rob Janering (Crowe UK) considers how to
avoid these.
Understanding the FIG regime
Jo Bateson
Jo Bateson (Mercer & Hole) provides a practical guide to the new regime.
Tax insurance: underwriting and policy insights
Laura Foley
Tom Cartwright
Laura Foley and Tom Cartwright (Certa Insurance Partners) share insights
on the insurer’s perspective when underwriting tax risks, and the impact on
policy structure.
International review for June 2025
Tim Sarson
The latest on the One Big Beautiful Bill Act, wealth taxes and more, reported
by Tim Sarson (KPMG).
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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