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ANALYSIS
Cutting edge analysis on tax issues.
No joy for JTIAC: an extension of the unallowable purpose principle
Constantine Christofi
The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).
Cryptoassets and the rise of the tax calculators
Ben Lee
In a sector reliant on software for tax solutions, Ben Lee (Andersen) explores the dangers of placing too much faith in ‘tax calculators’.
International review for June 2024
Tim Sarson
Your monthly review of latest developments, by Tim Sarson (KPMG).
Burlington in the UT: a clearer approach
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explains that the Upper Tribunal has
largely eschewed the FTT’s extensive reliance on UK domestic law cases on
‘purpose’ when determining whether a treaty anti-abuse provision applies.
Self's assessment: fiscal straitjackets
Heather Self
In this series, Heather Self examines tax issues in the headlines of the national press. This week, she examines the tax promises in the manifestos of the two major political parties - which are perhaps more notable for what
the parties say they won’t do, rather than what they will.
General Election 2024: tax in the manifestos
Liz Hudson
Jane Duncan
Liz Hudson and Jane Duncan (Evelyn Partners) report the tax policies of
the main parties – with additional comment from the IFS and Tax Policy
Associates.
Lessons on information notices and tax-related penalties from Baxendale-Walker
Matthew Greene
Following a recent case, we can probably expect HMRC to be less flexible
on taxpayer requests for more time to comply with information notices,
writes Matthew Greene (Stewarts).
Private client review for June 2024
Clare Wilson
Edward Reed
A new Finance Act and several recent tribunal decisions are reviewed by Clare Wilson and Edward Reed (Macfarlanes).
Winners and losers under the non-dom reforms
Emma Chamberlain
Emma Chamberlain OBE (Pump Court Tax Chambers) considers the new regime for non-doms from April 2025 and reviews the likely impact of the changes.
Football agents’ fees and dual representation
Pete Hackleton
David Lloyd
HMRC are taking a tougher line on agents’ fees but on some issues they appear to have misunderstood what happens in practice, write David Lloyd and Pete Hackleton (Saffery).
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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
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
Requirement to file CIS nil returns
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Tax agent registration and financial services
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
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