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ANALYSIS
Cutting edge analysis on tax issues.
Tribunal support for ADR: stick or carrot?
Ben Elliott
Peter Nias
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent
practice statement and other measures supporting the greater use of ADR.
The VAT review for June 2025
Gary Barnett
Joao Martinho
This month’s review by Joao Martinho and Gary Barnett (Simmons &
Simmons) covers the Court of Appeal decision in
Impact Contracting
Solutions
and two recent cases on the meaning of consideration.
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Naomi Lawton (A&O Shearman) finds much to welcome in the Government’s
latest policy statements.
Improving HMRC’s approach to dispute resolution
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
International review for May 2025
Tim Sarson
US developments dominate the headlines in this month’s update by
Tim Sarson (KPMG).
The Court of Appeal’s real-world view on the exemption for insurance intermediary services
Dr Michael Taylor
Dr Michael Taylor (PwC) considers whether Henderson LJ’s judgment in
WTGIL could bring all sorts of intermediary services back within the scope of
the VAT insurance exemption.
Beyond the billions: how the 100 Group’s tax contribution reflects a broader corporate responsibility
David Gordon
The discussion about tax responsibility should go beyond the rate of tax
companies pay, writes David Gordon (100 Group Taxation Committee).
Lifecycle of a transaction: Tax protections and W&I
Matt Davies
Elizabeth Emerson
Matt Davies and Elizabeth Emerson (DLA Piper) consider core tax
protections in share purchase agreements, and how they are impacted by tax
warranty and indemnity insurance.
Certainty in uncertain times
Erica Rees
Jenny Doak
Jenny Doak and Erica Rees (Weil, Gotshal & Manges) consider some of the
practical considerations surrounding the proposed process for providing
advance tax certainty for major projects.
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453
EDITOR'S PICK
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
1 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
2 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
3 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
4 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
5 /7
The new Securities Transfer Tax: business as usual?
Georgina West
6 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
7 /7
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
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
NEWS
Read all
Tax receipts rise, but borrowing exceeds OBR forecast ahead of Budget
Construction industry scheme compliance
CIOT urges legislative change on pre-development costs
CIOT backs faster land remediation relief but warns on planning link
Only one in ten highest earners pay top tax rate, says CenTax
CASES
Read all
Environmental Services Ltd v HMRC
Sir J Griffin v HMRC
Minerva Research Labs Ltd v HMRC
Other cases that caught our eye: 25 September 2026
J Scheckter v HMRC
IN BRIEF
Read all
Substantial
Modernising the taxation of distributions: why now?
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
Read all
J Scheckter v HMRC
Consultation tracker
Redrawing the line: modernising the taxation of distributions
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5
The new taxpayer duty to correct inaccuracies: practical consequences for M&A transactions