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ANALYSIS
Cutting edge analysis on tax issues.
Private client review for March 2026
Sophie Dworetzsky
From AI in court to IHT and judicial review, Sophie Dworetzsky
(Lombard Odier) reviews the latest developments.
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Henry Bennett-Gough
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in
Boston Consulting Group
and its implications for mixed member LLP structures.
How AI can help democratise tax administration
Stephen Daly
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
Tax and the City for March 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including
Sintra Global
, tax adviser registration and HMRC’s large business compliance approach.
Mixed member partnerships: anti-avoidance rules
A back to basics guide from Lexis®+ UK Tax.
HMRC’s Digital Disclosure Service: insights from practice
Jan Kolasa
Ben Webster
Tom O’Reilly
Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
HMRC’s Customer Compliance Group explained
Amit Puri
Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.
BTR late than never: SDLT overpayment relief
Helen Coward
‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.
Headless chickens: Morrisons and the FTT’s supervisory jurisdiction
Jack Prytherch
Yousuf Chughtai
The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC suggest SDLT payments may trigger adviser registration rules
NIC (Employer Pensions Contributions) Act receives royal assent
CIOT raises concerns over large business compliance burden
Commonwealth Games income tax regulations
CIOT calls for modernisation of treaty clearance process
CASES
Read all
Professional Game Match Officials Ltd v HMRC
M Parker v HMRC
T Kwok v HMRC
Other cases that caught our eye: 8 May 2026
HMRC v Burlington Loan Management DAC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Project Snowball
Transfer pricing changes: foreign exchange
HMRC issue Spotlight 63a on hybrid partnership property schemes
HMRC manual changes: 1 May 2026
Protected foreign source income: limits exposed