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ANALYSIS
Cutting edge analysis on tax issues.
Ask an expert: EOTs v MBOs
Paul Townson
James Flint
Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.
Registration of tax advisers: proportionality questions
Catherine Hill
Catherine Hill (White & Case) questions whether the proposed tax adviser registration regime is a proportionate response to the Government’s aim of raising standards.
HMRC’s ‘adventurism’ and the burden of proof in penalty appeals
Michael L Firth KC
The Court of Appeal’s reasoning in
Sintra Global
misses key principles and authorities, writes Michael Firth KC (Gray’s Inn Tax Chambers).
Joint ventures: applying ESC D33 in practice
Ceinwen Rees
Caroline Inker
Caroline Inker and Ceinwen Rees (Kirkland & Ellis) explore the impact of ESC D33 on contractual payments made in less-than-straightforward share purchase scenarios.
Legal certainty and the Inco principle
Dr Michael Taylor
Dr Michael Taylor (PwC) examines three recent cases where the FTT ignored the plain wording of legislation.
Import VAT and non-owners
Andrew Clarke
Mark Simm
Mark Simm and Andrew Clarke (Deloitte) assess the impact of HMRC’s strict ‘owner only’ stance on recovery of UK import VAT.
The VAT review for February 2026
Jo Crookshank
Gary Barnett
This month’s update by Jo Crookshank and Gary Barnett (Simmons & Simmons) covers share sales, substance over form and single supplies.
Ask an expert: Image rights, offshore structures and UK tax exposure
Sarah Richards
Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.
Tax Journal's 2025 Budget coverage
Full coverage of the 2025 Budget.
Ask an expert: The ‘dog-leg’: a way to fund non-dom divorces while preserving clean capital?
Henry Lowe
Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment
now that the non-dom regime has been abolished.
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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