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ANALYSIS
Cutting edge analysis on tax issues.
Challenging the NICs Bill
Baroness Neville-Rolfe DBE CMG
The Shadow Treasury Minister in the House of Lords, Baroness Neville-
Rolfe DBE CMG, explains why and how the Opposition challenged the
Government’s NIC changes in the House of Lords.
The Reserved Investor Fund: a practitioner guide
Paul Shaw
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
Tax and the City review for May 2025
Zoe Andrews
Mike Lane
The application of
Ramsay
in a recent case and HMRC’s revised guidance
on salaried members are among the topics covered in this month’s review
by Mike Lane and Zoe Andrews (Slaughter and May).
Losses and major changes in the trade or business
John Angood
James Hewitt
John Angood and James Hewitt (BDO) provide a back to basics guide.
Equitable ownership and VAT: legal mysteries and potential answers
Fabian Barth
VAT law struggles to address the distinction between legal and equitable
ownership, but case law can provide some answers, writes Fabian Barth
(Alvarez & Marsal).
Tax Update Spring 2025
A report by Lexis®+UK Tax on the tax policy announcements.
Whistleblowing
David Whiscombe
The Government’s plan to launch a new tax whistleblower scheme raises a
number of questions – and it’s not clear how many have been fully thought
through, writes David Whiscombe.
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines recent Government
proposals which, he says, leave little doubt that tax avoidance, like tax evasion,
is to be regarded as a criminal activity.
Tariffs: a history of American protectionism
Duncan Weldon
President Trump’s approach to tariffs fits within a longer history of American
protectionism, writes economist Duncan Weldon, but was that approach ever
successful?
Lifecycle of a transaction: transfer pricing considerations
Uwe Zoellner
Rachit Agarwal
Monia Volpato
Rachit Agarwal, Monia Volpato and Uwe Zoellner (DLA Piper) set
out the transfer pricing aspects that should be considered during the
acquisition process.
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444
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