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ANALYSIS
Cutting edge analysis on tax issues.
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.
Tribunal support for ADR: stick or carrot?
Ben Elliott
Peter Nias
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent
practice statement and other measures supporting the greater use of ADR.
The VAT review for June 2025
Gary Barnett
Joao Martinho
This month’s review by Joao Martinho and Gary Barnett (Simmons &
Simmons) covers the Court of Appeal decision in
Impact Contracting
Solutions
and two recent cases on the meaning of consideration.
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s
latest policy statements.
Improving HMRC’s approach to dispute resolution
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
International review for May 2025
Tim Sarson
US developments dominate the headlines in this month’s update by
Tim Sarson (KPMG).
The Court of Appeal’s real-world view on the exemption for insurance intermediary services
Dr Michael Taylor
Dr Michael Taylor (PwC) considers whether Henderson LJ’s judgment in
WTGIL could bring all sorts of intermediary services back within the scope of
the VAT insurance exemption.
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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