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IPT
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BEPS
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Withholding taxes
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ANALYSIS
Cutting edge analysis on tax issues.
Divide and conquer: the partition demerger story
Matt Cummings
Colin Askew
Alisha Kouser
Untangling a business from a group (or single entity) in a tax neutral fashion
takes time and care. Colin Askew, Matt Cummings and Alisha Kouser
(Eversheds Sutherland) provide a case study considering the tax issues on a
partition demerger.
Revisiting the boilerplate withholding tax clause via 1962 (and beyond)
Ceinwen Rees
Serene Ho
Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate
clauses exist and why it’s important to check that they are included in
the contract.
The new Labour government: challenges and opportunities
Bezhan Salehy
David Gauke
David Gauke and Bezhan Salehy (Macfarlanes) share their Treasury insights on
the practical challenges facing the new administration.
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
Scale to sale: tax considerations when selling a UK business
Liz Hunter
Nicola Simmons
Moustapha Hammoud
Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya)
explain the personal, employment and corporate tax issues.
Private client review for July 2024
Kazia Gagg
Edward Reed
Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for
private clients under the new Labour government and comment on a number
of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.
The dirty dozen
James Quarmby
The 12 most annoying stereotypes about the world of tax, according to James Quarmby (Stephenson Harwood).
Beneficial ownership: practical applications
Helen Buchanan
Gabrielle Van der Haegen
Matthew Everett
Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.
Tax and the City review for July 2024
Zoe Andrews
Mike Lane
The decisions in
JTI
,
Altrad
and
Burlington
are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Summer 2024
Harry Smith
Adam Craggs
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
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430
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
Read all
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
Eurocent (Buckingham) Ltd v HMRC