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IPT
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ANALYSIS
Cutting edge analysis on tax issues.
Tax grouping (part II): capital gains groups
Maddy Potthast
Gavin Little
Continuing the series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) explain the rules for capital gains groups and the
pitfalls to watch out for in practice.
Yorkshire Agricultural Society, consistent interpretation and the continued relevance of EU law
Edd Thompson
Edd Thompson (Forvis Mazars) explores the Upper Tribunal’s approach to
the principle of ‘consistent interpretation’ on the VAT charitable fundraising
exemption and considers its potential relevance in the post-Brexit era.
Judicial review in tax disputes
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) set out the general principles and the
practical aspects of advancing a judicial review claim.
International review for February 2025
Tim Sarson
This month’s review by Tim Sarson (KPMG) includes insight on the latest
developments from the US Administration and the European Community.
Helping vulnerable individuals: a guide for tax professionals
Dawn Register
Chris Holmes
How do you spot the signs, and what steps should you take? Chris Holmes and Dawn Register (BDO) provide a practical guide for tax advisers.
Transfer pricing: why returns are rarely risk-free
Phil Maggs
Phil Sneade
Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Tristan Thornton
Joseph Howard
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
Private client review for February 2025
Dominic Lawrance
Sophie Dworetzsky
Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).
Sonder Europe and serviced apartments: TOMS or no TOMS?
Damon Wright
Damon Wright (K3 Tax Advisory) questions the Upper Tribunal’s ruling on the VAT Tour Operators Margin Scheme.
If I could turn back time: encouragement for taxpayers seeking rectification
Arthur Wong
Ben Elliott
Ben Elliott and Arthur Wong (Pump Court Tax Chambers) explain why
there are grounds for optimism for taxpayers seeking to rely on rectification as
a potential means of resolving disputes with HMRC.
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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