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ANALYSIS
Cutting edge analysis on tax issues.
International review for October 2024
Tim Sarson
The proposed US regulations on Corporate Alternative Minimum Tax, an
important CJEU decision on state aid and the Irish Budget are among the
recent developments reviewed by Tim Sarson (KPMG).
In conversation with... Melanie Hall KC
Anthony Inglese
Melanie Hall KC
Melanie Hall KC (Monckton Chambers) talks to Anthony Inglese CB about
life at the Tax Bar and beyond.
Avoiding avoidance
Graham Webber
Graham Webber (WTT Consulting) explains why a more radical approach is
needed to tackling unacceptable avoidance.
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
Brindleyplace Holdings: is s 75A (Hann)over now?
Edward Hardy
Helen Coward
Helen Coward and Edward Hardy (Simmons & Simmons) examine a
recent FTT decision on SDLT, property investment partnerships and the
anti-avoidance rule in s 75A.
Home and away: how to go non-resident after McCabe
Oliver Marre
The Upper Tribunal’s decision in McCabe shows how difficult it can be to
challenge findings of fact when confronted with multi-factorial tests, writes
Oliver Marre (5 Stone Buildings).
Private client review for October 2024
Clare Wilson
Edward Reed
Edward Reed and Clare Wilson (Macfarlanes) review the latest cases on EIS,
BPR, reasonable excuse, and the principles of open justice and privacy.
Is direct effect in VAT still alive in 2024?
Fabian Barth
Fabian Barth (Alvarez & Marsal) challenges HMRC’s view that direct effect
ceased to exist in VAT from 1 January 2024.
Transfer pricing compliance: a guiding hand and a warning
Simon Wood
HMRC are clearly not happy with the standard of analysis and documentation
that they are currently seeing, writes Simon Wood (BDO).
Why can’t we love HMRC like we love the NHS?
Jonathan Riley
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
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
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Finance Bill 2026 amendments