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ANALYSIS
Cutting edge analysis on tax issues.
When tax disputes collide: the hidden traps in parallel HMRC and civil proceedings
Anastasia Nourescu
James Le Gallais
Parallel HMRC and civil proceedings are best handled not as two separate
problems to be dealt with in sequence, but as a single, interconnected strategic
challenge, write James Le Gallais and Anastasia Nourescu (Stewarts).
Legal advice privilege and tax advice: scope, limits and interaction with HMRC
Jason Collins
Lauren Redhead
Legal advice privilege (LAP) remains a vital right for taxpayers, but its
boundaries are far from settled. Jason Collins and Lauren Redhead (DLA
Piper) examine LAP in a tax context, including the recent decision in Aabar v
Glencore which extends privilege to intra-client group communications.
Show and tell: the changing face of disclosure in tax litigation
Jack Prytherch
Yousuf Chughtai
The starting point Under Rule 27 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules, SI 2009/273 (as amended) (the FTT rules), each party in standard or complex cases need only provide the other with a list of documents...
Measuring tax gaps 2026
Heather Self
Heather Self (Blick Rothenberg) analyses HMRC’s latest tax gap figures, and
explains why annual comparisons can mislead and why compliance activity
alone will not close the gap.
International review for July 2026
Tim Sarson
In this month’s update, Tim Sarson (KPMG) tracks the EU Tax Omnibus and
DAC recast proposals, Dutch Box 3 reform and digital services tax debate,
noting the political barriers to implementation.
Legislation Day: draft Finance Bill 2027
A detailed report by Lexis+® UK Tax, with additional practitioner insight.
Legislation Day 2026: The Foreign Branch Exemption reforms
Andrew Parkes
Closing a hole that became bigger than expected.
Legislation Day 2026: The securities transfer tax
Richard Sultman
Rob Sharpe
Key points to note.
Legislation Day 2026: Alas, poor stamp duty! I knew it
Philip Ridgway
An affectionate farewell to an ancient tax – and a group relief question its replacement is yet to answer.
Legislation Day 2026: Simplifying treaty relief from WHT on interest paid overseas
Eloise Walker
Not really a simplification at all.
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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
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
Read all
Consultation tracker
J Scheckter v HMRC
The new taxpayer duty to correct inaccuracies: practical consequences for M&A transactions
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5
Redrawing the line: modernising the taxation of distributions