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ANALYSIS
Cutting edge analysis on tax issues.
The 2025 loan charge review and Government response: the final chapter?
David Pett
All but one of the loan charge review’s ‘hard’ recommendations have been
accepted. David Pett (Temple Tax Chambers) assesses both the review and
the Government’s response – and considers the implications for affected
taxpayers and the new settlement opportunity.
Saunders: new uncertainty for contractual employee incentive arrangements
Peter North
Rob Sharpe
Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal
ruling on the taxation of stock appreciation rights – a decision that introduces
fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.
The VAT review for December 2025
Katie Oliver
Gary Barnett
Katie Oliver and Gary Barnett (Simmons & Simmons) review recent
VAT developments on factoring, public bodies, input VAT evidence and
intermediaries’ recovery rights.
Risky business: the basics and use cases of tax insurance
Kate Pearson
Annabelle Trotter
Helen Coward
The tax insurance market has grown significantly. Helen Coward (Simmons &
Simmons) speaks with Annabelle Trotter and Kate Pearson (Howden) about
how it is now used across an increasingly broad range of transactions.
International review for December 2025
Tim Sarson
Tim Sarson (KPMG) reports key international developments, led by the OECD’s
long-awaited guidance on permanent establishments for remote workers,
alongside major updates from Brazil, Canada, the EU and the CBAM regime.
More of a stew than a smorgasbord?
Chris Sanger
The Chancellor managed to deliver a package that felt both familiar and, in
places, surprisingly bold, writes Chris Sanger (EY).
Budget 2025: Economics view: One and done… becomes two and done
Duncan Weldon
A year ago, the Chancellor, unveiling around 40bn of annual tax rises in her first Budget, was keen to emphasise that she would not be back asking for more. This was a one and done approach. The still new Government hoped for one painful...
Budget 2025: Curtailing TOMS
Etienne Wong
And the Chancellor said: And I will improve competition in our taxi industry by ending ride-hailing companies use of a discount scheme intended for coach tours In 35 years of practice, I have never heard the VAT Tour...
Budget 2025: Energy: the fiscal regime post-EPL
Paul Rogerson
No changes were announced in the Budget to the rates of ring fence corporation tax, supplementary charge to corporation tax or the energy profits levy (EPL). There was no announcement on any change to EPL and therefore this will remain in place until...
Budget 2025: Gambling duty reform: higher rates where higher risk of harm
Ceri Stoner
The taxation of the much-maligned gambling sector has been subject to increasing scrutiny by the Treasury in recent years, culminating in a Treasury consultation in April 2025 and a pre-budget review by the Treasury Committee in November. It is...
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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