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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for March 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in
Lloyds Asset Leasing
and
Royal Bank of Canada
, as well
as HMRC’s plans to update guidance on the salaried member rules.
RBC: from the island of literal interpretation to the continental shelf
Kyle Rainsford
Victoria Hine
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Findings of fact are stubborn things: A Taxpayer v HMRC
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys)
consider the implications of the Court of Appeal judgment.
Personal tax reform: a not-so-modest proposal
George Gillham
Perhaps it is now time for a radical simplification of personal taxation?
George Gillham (Fieldfisher) sets out some ideas for a fairer and better tax
system.
Barclays’ tech outage: penalties, interest and HMRC’s constitutional boundaries
Jessica Kemp
Catherine Hill
The January Barclays tech outage shines a light on the sometimes uncompromising
interest and penalty regimes facing taxpayers which, in this context, demand
flexibility, write Jessica Kemp and Catherine Hill (White & Case).
The VAT review for March 2025
Jo Crookshank
Gary Barnett
Jo Crookshank and Gary Barnett (Simmons & Simmons) review two
decisions on input VAT recovery on a supply of land and student union
catering from a bar, and the consultation on UK e-invoicing.
Registration of tax advisers: proportionality questions
Catherine Hill
Catherine Hill (White & Case) questions whether the proposed tax adviser registration regime is a proportionate response to the Government’s aim of raising standards.
HMRC’s ‘adventurism’ and the burden of proof in penalty appeals
Michael L Firth KC
The Court of Appeal’s reasoning in
Sintra Global
misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).
Joint ventures: applying ESC D33 in practice
Ceinwen Rees
Caroline Inker
Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.
Legal certainty and the Inco principle
Dr Michael Taylor
Dr Michael Taylor (PwC) examines three recent cases where the FTT ignored the plain wording of legislation.
Go to page
of
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