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ANALYSIS
Cutting edge analysis on tax issues.
Ask an expert: EMI v CSOP options post-April 2026
Veronika Lipinska
Matthew Emms
Matthew Emms and Veronika Lipinska (BDO) consider whether, following
the 2025 Budget reforms, a CSOP should now revert to EMI, and in what
circumstances CSOP or unapproved options might still be relevant.
Ask an expert: Buy now, pay later: deferred consideration in share sales
Dulcie Daly
Dulcie Daly (Goodwin) considers the complexities that can arise for
taxpayers when share sale proceeds include deferred amounts.
Ask an expert: EOTs v MBOs
Paul Townson
James Flint
Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.
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.
Import VAT and non-owners
Andrew Clarke
Mark Simm
Mark Simm and Andrew Clarke (Deloitte) assess the impact of HMRC’s strict ‘owner only’ stance on recovery of UK import VAT.
The VAT review for February 2026
Jo Crookshank
Gary Barnett
This month’s update by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers share sales, substance over form and single supplies.
Ask an expert: Image rights, offshore structures and UK tax exposure
Sarah Richards
Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.
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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
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