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ANALYSIS
Cutting edge analysis on tax issues.
The FA 2016 rules on transactions in UK land
Andrew Scott
New rules enacted in Finance Act 2016 were effective from 5 July in relation to the income tax and corporation tax treatment of transactions concerning land in the UK. Although the rules apply to structures involving offshore developers and much...
BEPS Action 14: OECD detail on ‘MAP’ procedures
Rupert Shiers
Julian Brown
The OECD has released further documents relating to the Mutual Agreement Procedure. Julian Brown and Rupert Shiers (Hogan Lovells) report.
The FA 2016 rules on transactions in UK land
Andrew Scott
Andrew Scott (Pinsent Masons) reviews the new rules in relation to the income tax and corporation tax treatment of transactions concerning land in the UK.
Ingenious: Supreme Court rules HMRC in breach of confidence
Gideon Sanitt
Gideon Sanitt (Macfarlanes) reviews the decision in
Ingenious Media
and to what extent HMRC will be held to its duty of confidentiality.
BEPS Action 4 for banks – or not?
Eloise Walker
Eloise Walker (Pinsent Masons) considers the latest OECD proposals for banks under the BEPS Action 4 interest restrictions, and what they might mean for the UK banking sector.
Carried interest: funds of funds and the IBCI rules
Catherine Sear
Catherine Sear (Proskauer) considers how the income-based carried interest rules introduced by Finance Act 2016 apply in a fund of funds context.
Private client briefing for October 2016
Judith Robertson
Andrew Goldstone
Andrew Goldstone and Judith Robertson (Mishcon de Reya) review the latest tax developments affecting private clients.
International briefing for October 2016
Tim Sarson
Tim Sarson (KPMG) assesses the latest developments that matter in the international tax arena.
The curious case of VCS
Etienne Wong
Etienne Wong (Old Square Tax Chambers) considers where the Upper Tribunal judgment in
Vehicle Control Services
sits in the context of EU jurisprudence.
The proposed changes to corporation tax loss relief
Jack Lewis
Sarah Lane
Sarah Lane and Jack Lewis (FTI Consulting) look at the background and the effect of the proposals using worked hypothetical examples.
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EDITOR'S PICK
Budget 2026: options for taxing wealth
Dom Rothbarth
1 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
2 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
3 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
4 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
5 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
6 /7
The new Securities Transfer Tax: business as usual?
Georgina West
7 /7
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
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
NEWS
Read all
Tax Journal authors for August and September
Labour conference backs wealth and windfall taxes, as Burnham pledges national care service
Welsh rates of income tax: HMRC report
New VAT guidance on partnership details
Further Scottish visitor levy changes
CASES
Read all
Jumpman Gaming Ltd v HMRC
K Poznic v HMRC
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Other cases that caught our eye: 2 October 2026
Environmental Services Ltd v HMRC
IN BRIEF
Read all
Loans to participators: s 455
Modernising the taxation of distributions
HMRC’s new anti-avoidance information notice powers
Substantial
Modernising the taxation of distributions: why now?
MOST READ
Read all
Modernising the taxation of distributions: why now?
Environmental Services Ltd v HMRC
Loans to participators: s 455
HMRC powers and the taxpayer relationship: when is enough, enough?
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another