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ANALYSIS
Cutting edge analysis on tax issues.
APR and BPR reform: time to make hay while the sun shines?
Emma Haley
Hayden Bailey
After a wait of four months for more detail on the changes, what does
the consultation document now tell us? While there are some helpful
clarifications, not all of the concerns are addressed, write Hayden Bailey
and Emma Haley (Boodle Hatfield).
Initiative and the tax tribunal: a higher calling?
Bridget Winters
Calum Young
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Suboptimal access: HMRC and data requests
Robert Waterson
Lucy Collins
Robert Waterson and Lucy Collins (Eversheds Sutherland) examine a recent
High Court ruling that could encourage individuals to challenge HMRC if
they feel their personal data rights are being infringed.
Tax insurance: taxation of proceeds and gross-up
Laura Foley
Tom Cartwright
The taxation of insurance proceeds is relevant for sizing a policy limit.
Laura Foley and Tom Cartwright (Certa Insurance) consider various
practical scenarios and implications.
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.
Go to page
of
442
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
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
Requirement to file CIS nil returns
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker