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ANALYSIS
Cutting edge analysis on tax issues.
The CBAM trilemma
Joshua Stevens
The UK’s Carbon Border Adjustment Mechanism launches in January 2027.
Joshua Stevens (Pump Court Tax Chambers) explains what’s proposed – and
why it risks exacerbating trade tensions at a time of rising protectionism.
R&D Disclosure Service: the best route to resolution?
Jon Claypole
Jack Sloggett
Jon Claypole and Jack Sloggett (BDO) welcome HMRC’s new R&D
Disclosure Service but explain it is not suitable in all circumstances.
International review for January 2025
Tim Sarson
Tim Sarson (KPMG) reviews the latest developments and looks ahead at what
to expect in 2025.
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
Andrew Solomon
During Trump’s second presidential term, the spectre of tax cuts expanding the US federal budget deficit will fuel fierce debates between fiscally conservative and ‘pro-growth’ Republicans, write Donald L Korb and Andrew Solomon (Sullivan & Cromwell).
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
Navigating the protective assessment maze with Jeffries & Sons
Bryn Reynolds
Bryn Reynolds (Pinsent Masons) examines the recent
Jeffries
case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
Pillar Two one year on: what have we seen and where are we going?
Kara Heggs
Jisun Choi
Jisun Choi and Kara Heggs (Skadden, Arps, Slate, Meagher & Flom) take stock of some of the practical issues arising from Pillar Two.
Fixing the wrong problem? The need to tackle shadow advisers
Ray McCann
Unless shadow advisers are effectively regulated and HMRC can act closer to
real time, we will soon once again be facing calls for regulation of the whole
profession, writes Ray McCann.
GCH Corporation: did HMRC forget to bring their gun to the sword fight?
David Whiscombe
HMRC may have overlooked their own statement of practice which says that
such a transfer is in general a disposal, writes David Whiscombe.
Tax grouping (part 1): group relief and tax groupings
Maddy Potthast
Gavin Little
In the first in a series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) focus on the conditions for corporation tax loss
relief via group relief.
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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