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ANALYSIS
Cutting edge analysis on tax issues.
Medpro: better late than never
Stacey Cranmore
Medpro
frees the tribunal from Martland’s fetters, writes Stacey Cranmore
(Pump Court Tax Chambers).
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
Private client review for October 2025
Sophie Dworetzsky
In this month’s report, Sophie Dworetzsky (Lombard Odier) reports growing
concerns over draft tax reforms, and the latest court rulings on retrospective
tax status and trustee replacement.
OBBBA: one big beautiful guide for non-US tax professionals
Paul McColgan
Jason Groves
Mark Saunderson
Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out
some recommendations for UK professionals advising businesses with large
US operations.
No escape: the new IHT tax rules for pensions
Harriet Betteridge
Which pensions will be taxed? Who is responsible for reporting and paying
the tax? What’s the impact on planning? Harriet Betteridge (Charles Russell
Speechlys) examines some key questions surrounding the proposed legislation.
Forex: recent UK tax developments
Tamar Ruiz
Matthew Mortimer
Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent
changes to the UK taxation of foreign exchange gains and losses.
Tax and the City review for October 2025
Zoe Andrews
Mike Lane
The OECD’s ‘side-by-side’ system, the
Prudential
ruling and HMRC’s new
technical note on the reserved investor fund regime are examined in this
month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
In conversation with... Paul Johnson
Anthony Inglese
Paul Johnson
Paul Johnson, former Director of the Institute for Fiscal Studies, talks to
Anthony Inglese CB about his career in economics and his views on UK
fiscal policy.
Legislating against promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.
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EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
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
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
New HMRC withholding tax guidance
Tax Journal's 2026 Budget coverage
Budget 2026: Sovereign immunity - a more considered reform
Budget 2026: the tax measures