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ANALYSIS
Cutting edge analysis on tax issues.
International review for March 2025
Tim Sarson
Tim Sarson (KPMG) reports the growing divergence in ideology between two
of the world’s most powerful blocs, the US and the EU.
Elborne: trusting that the loan will be deducted
Anthony Nixon
Anthony Nixon (Paris Smith) examines the first judicial ruling to accept that the double trust home loan scheme works to save inheritance tax.
Bryan Robson: when image and IR35 don’t mix
David Harmer
A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).
EIS disqualifying arrangements: jumping through the Hoopla
Tom Wilde
Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.
Private client review for March 2025
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.
Criminal offences and prosecutions for tax fraud
Dan Williams
Adam Craggs
Adam Craggs and Dan Williams (RPC) provide a back to basics guide.
APR and BPR reform: time to make hay while the sun shines?
Emma Haley
Hayden Bailey
After a wait of four months for more detail on the changes, what does
the consultation document now tell us? While there are some helpful
clarifications, not all of the concerns are addressed, write Hayden Bailey
and Emma Haley (Boodle Hatfield).
Initiative and the tax tribunal: a higher calling?
Bridget Winters
Calum Young
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Suboptimal access: HMRC and data requests
Robert Waterson
Lucy Collins
Robert Waterson and Lucy Collins (Eversheds Sutherland) examine a recent
High Court ruling that could encourage individuals to challenge HMRC if
they feel their personal data rights are being infringed.
Tax insurance: taxation of proceeds and gross-up
Laura Foley
Tom Cartwright
The taxation of insurance proceeds is relevant for sizing a policy limit.
Laura Foley and Tom Cartwright (Certa Insurance) consider various
practical scenarios and implications.
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438
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
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
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Finance Bill 2026 amendments