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ANALYSIS
Cutting edge analysis on tax issues.
International review for September 2024
Tim Sarson
The Irish Apple state aid case and the US electoral candidates respective tax
policies are among the recent developments reviewed by Tim Sarson (KPMG).
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Corporation tax rate complexities for corporate LLP members
Emma Rawson
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
Private client review for September 2024
Damiano Sogaro
Edward Reed
Edward Reed and Damiano Sogaro (Macfarlanes) report on the latest on information notices, nudge letters, penalties and more.
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
Although the FTT’s recent decision in Barclays is disappointing news, there are some positives, writes Philippe Gamito (Baker McKenzie).
The last word on tax appeals
Malcolm Gammie CBE KC
The Supreme Court stands at the head of the UK’s judicial appeals system.
Malcolm Gammie CBE KC (One Essex Court) examines when permission
to appeal to the Supreme Court is likely to be granted, and considers how
taxpayers and HMRC are faring in securing permission.
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Tax and the City review for September 2024
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
Lycamobile: can phone bundles lead to VAT blunders?
Giles Salmond
Giles Salmond (Stewarts) examines an FTT decision covering a variety of
VAT issues, including the time of supply, the voucher rules and the use and
enjoyment provisions.
Reform of the international tax architecture: the UN fails to reach consensus
Philip Baker KC
Unbridgeable divides? Recent developments do not bode well for a successful outcome to the process of reforming the international tax architecture, writes Philip Baker KC OBE (Field Court Tax Chambers).
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EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
HMRC manual changes: 7 November 2025
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
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Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
MOST READ
Read all
Tyler Security Ltd v HMRC
Time to bring back Budget purdah?
‘Partnership NICs’: the impact on the asset management sector
Transfer pricing ‘high-value’ intragroup services
Consultation tracker