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ANALYSIS
Cutting edge analysis on tax issues.
FA 2025 EOT rules and the impact on valuations
Ritchie Tout
The recent changes to the Employee Ownership Trust rules bring the regime
back to its intended purpose – and may impact many valuations, writes
Ritchie Tout (Azets).
VAT and the management of Special Investment Funds: the last six years
Alex Tostevin
Etienne Wong
The application of this VAT exemption remains both complex and uncertain,
writes Alex Tostevin (Greenberg Traurig) and Etienne Wong (Old Square
Tax Chambers).
The clock is ticking on President Trump’s Tax Bill
Andrew Solomon
Andrew Solomon (Sullivan & Cromwell) explains why President Trump’s
plans for ‘one big, beautiful Bill’ are heading for one big, ugly negotiation.
TP, DPT and UTPP: twists, turns and transformations
Benjamin Crompton
Sarah Bond
Sarah Bond and Benjamin Crompton (Freshfields) examine the draft
legislation that amends certain aspects of the rules on transfer pricing and the
diverted profits tax.
Private client review for May 2025
Sophie Dworetzsky
In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys)
examines a case on distributions from an offshore company, a potentially farreaching
proposed change to the definition of permanent establishment and
the latest HMRC guidance.
Code of Practice 9 and discovery assessments
Michael Paulin
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s
broader view of tax fraud in its updated COP 9.
Time is money: how to mitigate late payment interest in tax disputes
Jack Prytherch
Jack Prytherch (Osborne Clarke) sets out the practical steps that taxpayers
can take to minimise delays in their disputes with HMRC and so mitigate any
additional interest charged.
Challenging the NICs Bill
Baroness Neville-Rolfe DBE CMG
The Shadow Treasury Minister in the House of Lords, Baroness Neville-
Rolfe DBE CMG, explains why and how the Opposition challenged the
Government’s NIC changes in the House of Lords.
The Reserved Investor Fund: a practitioner guide
Paul Shaw
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
Tax and the City review for May 2025
Zoe Andrews
Mike Lane
The application of
Ramsay
in a recent case and HMRC’s revised guidance
on salaried members are among the topics covered in this month’s review
by Mike Lane and Zoe Andrews (Slaughter and May).
Go to page
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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