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ANALYSIS
Cutting edge analysis on tax issues.
The Scottish Budget 2025/26: steady as she goes, but with some stings in the tail
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) review the Scottish Budget, including the new
Scotland’s tax strategy
publication which contains a wide range of substantive possibilities for change.
In conversation with... Malcolm Gammie CBE KC
Anthony Inglese
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases. He talks to Anthony Inglese about life at the Tax Bar and beyond.
The tractor tax
Stuart Maggs
The proposed IHT reforms seem to attack the farmers they should protect and
protect the people they should tax, writes Stuart Maggs (Howes Percival).
A third route to exit: tax consequences of continuation fund transactions
May Smith
Emily Szasz
May Smith and Emily Szasz (Freshfields) examine some of the key
tax considerations that arise in relation to the transfer of assets into a
continuation fund.
The Foreign Income and Gains regime: employer considerations
Nisus Larsen
Claire Murray
The UK is likely to become more attractive in the short term for overseas
employees but less attractive in the medium to long term, Claire Murray and
Nisus Larsen (Alvarez & Marsal) explain.
Dealing with non-resident CGT issues on transactions
Akash Mehta
Jenny Doak
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key
considerations for M&A transactions.
Insuring M&A tax risks: practical considerations for buyers
Shayaan Zaraq Bari
Nicholas Gardner
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining
W&I insurance with other tools may help bridge any gaps in tax risk coverage
and maximise protection for buyers.
The VAT review for December 2024
Gary Barnett
In this month’s review, Gary Barnett (Simmons & Simmons) reviews the
agreement on ViDA, the consultation responses on CBAM in the UK and the
impact of an Upper Tribunal decision on supplies by public bodies.
Cards face up? HMRC’s approach to the duty of candour
Robert Waterson
Rebekka Sandwell
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The Supreme Court’s ruling in Cobalt Data Centre: golden opportunity lost
Sam Wardleworth
Steven Porter
The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
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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