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ANALYSIS
Cutting edge analysis on tax issues.
New guidance on 1.5% stamp tax charge and s 138 clearances
Jack Jones
David Wilson
After an uneventful Budget and Tax Administration and Maintenance Day, and with little by way of legislative proposals (except for those advising non-doms), some of the most interesting tax developments of recent months have come in the form of...
Back to basics: Closure notices and the appeals process
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) provide a refresher guide.
International review for May 2024
Tim Sarson
Netherland’s new coalition government’s tax plans, the latest Canadian and Australian Budgets and several EU developments are included in this month’s review by Tim Sarson (KPMG).
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Hargreaves in the Court of Appeal: a return to orthodoxy on withholding taxes?
Dominic Robertson
Deepesh Upadhyay
Deepesh Upadhyay (Eversheds Sutherland) and Dominic Robertson
(Slaughter and May) examine one of the most important withholding tax
cases in years.
Selling an EOT-owned company: when can it be done and what are the consequences?
David Pett
David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider
what is in the best interests of the beneficiaries as a class, how the sale
proceeds are to be distributed and the tax consequences of any sale.
When does the ratio of a judgment have no precedential value?
Michael Ridsdale
Gemma Williams
Exceptions to the doctrine of precedent do exist but, as a recent case
illustrates, they will be rarely applied in practice, write Michael Ridsdale and
Gemma Williams (Wedlake Bell).
Private client review for May 2024
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases
concerning entrepreneurs’ relief, PPR and SDLT.
The taxation of carried interest: where are we now?
Ben Symons
The taxation of private equity executives has become highly politically contentious as we head into the next election. An Opposition policy costing document released in February this year (bit.ly/4dol4do) shows that the Labour Party plans to tax the...
Non-dom reform: the proposals
Rebecca Sheldon
Rebecca Sheldon (Old Square Tax Chambers) considers the proposals from the Conservative Party that give a broad indication as to how the new regime is intended to operate, and what might be expected if the Labour Party wins the General Election.
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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
Nimbus: The Disability Consultancy Service Ltd v HMRC