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ANALYSIS
Cutting edge analysis on tax issues.
VAT on private school fees: 10 takeaways
Etienne Wong
Etienne Wong (Old Square Tax Chambers) provides a guide to the key points
from the Labour government’s introduction of VAT on private school fees.
Disapplication of the option to tax: issues for landlords and tenants
Anisha Polson
Paul Beausang
The VAT option to tax disapplication rules pose a conundrum for landlords
and tenants. Paul Beausang and Anisha Polson (Eversheds Sutherland)
consider what should be done.
‘Golden bricks’: when does construction really begin for VAT purposes?
Michael Ridsdale
Richard Dalton
Richard Dalton (BDO) and Michael Ridsdale (Wedlake Bell) challenge the
orthodox view that a dwelling is regarded as being constructed for VAT purposes
when it has reached ‘golden brick’.
International review for July 2024
Tim Sarson
Pressure grows for a global wealth tax. This and other recent developments in
international tax are examined by Tim Sarson (KPMG).
Tax risk insurance claims explained
Julian Feiner
W&I and specific tax risk insurance has proliferated and tax claims are
emerging. Julian Feiner (DAC Beachcroft) explains the unique framework
for claims.
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.
Go to page
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438
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
Nimbus: The Disability Consultancy Service Ltd v HMRC