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ANALYSIS
Cutting edge analysis on tax issues.
The VAT review for May 2025
Jo Crookshank
Gary Barnett
VAT developments concerning transfer pricing adjustments, tripartite
arrangements and the Tour Operators Margin Scheme are examined in this
month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
Oliver Twentyman
Many advisers appear to be adopting a contrived and narrow interpretation of
the word ‘preferential’ in an attempt to provide commercial protection to EIS
investors on a winding-up, warns Oliver Twentyman (Azets).
Capital allowances: uncertainty over design costs resolved by Court of Appeal
Paul Farey
Paul Farey (AECOM) assesses the impact of the Court of Appeal’s judgment
in
Gunfleet Sands
.
Challenging HMRC’s debt management actions: lessons from Local Fuel
Daniel Williams
Michelle Sloane
A recent High Court decision provides valuable guidance for taxpayers
seeking to challenge enforcement action taken by HMRC’s Debt Management
team, write Michelle Sloane and Daniel Williams (RPC).
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
International review for April 2025
Tim Sarson
Key policy developments in the US and an AG opinion on VAT on transfer
pricing are among the topics examined this month by Tim Sarson (KPMG).
HMRC’s revised R&D guidance: the end of a long and winding road?
James Dudbridge
HMRC’s updated guidance marks the end of a long and winding road for
R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).
Finance Act 2025: special report
Ros Martin
A detailed report of this year’s Finance Act.
FA 2025 review: VAT on private school fees: a lack of clarity
Etienne Wong
On its face, the new legislation imposing VAT on the provision of education by a private school seems straightforward well put-together, even. It takes little time to realise, however, that perhaps the Government should have taken a couple...
FA 2025 review: The loans to participators regime no more (re)paying your way
Hugh Gunson
With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The loans to participators rules in...
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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