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ANALYSIS
Cutting edge analysis on tax issues.
The Temporary Repatriation Facility opportunity
Alice Pearson
The Temporary Repatriation Facility could create significant tax savings
for some. Alice Pearson (Mercer & Hole) highlights some practical
considerations and areas of complexity.
The VAT review for August 2025
Gary Barnett
Joao Martinho
Supplies of management services, economic reality and the application of the
Ablessio principle are among the topics covered in this month’s VAT update
by Joao Martinho and Gary Barnett (Simmons & Simmons).
Scatola: 20 years to raise s 75A discovery assessments
Sinisa Butina
Angela Savin
Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper
Tribunal’s reasoning in
Scatola
and the broader ramifications for taxpayers
seeking certainty and finality to their SDLT affairs.
Five (S)EIS pitfalls for the unwary
Philip Hare
Administrative errors can jeopardise SEIS and EIS relief, even when advance
assurance has been received from HMRC, as Philip Hare (Philip Hare &
Associates) explains.
Mining for information: preparing for CARF
Jack Prytherch
Yousuf Chughtai
CARF may be just the beginning of a new age of tax enforcement and
scrutiny for the crypto industry, write Yousuf Chughtai and Jack Prytherch
(Osborne Clarke).
International review for July 2025
Tim Sarson
Tim Sarson (KPMG) examines the latest developments from around the globe.
You can Reid all about it (because it’s not privileged)
Kyle Rainsford
Victoria Hine
Kyle Rainsford and Victoria Hine (Addleshaw Goddard) examine what is
believed to be the first case which has applied the iniquity principle in relation
to tax advice.
Transformation Roadmap
Paul Aplin OBE
HMRC’s new roadmap heralds a step-change in the department’s digital
ambition, writes Paul Aplin OBE.
Business investment relief: where angels fear to tread?
Dominic Lawrance
Jonathan Rothwell
Jonathan Rothwell and Dominic Lawrance (Charles Russell Speechlys)
consider an Upper Tribunal decision that highlights significant issues in the
application and potential pitfalls of business investment relief.
OBBBA: a new era in Republican tax legislation
Andrew Solomon
Aharon Friedman
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the
One Big Beautiful Bill as a whole and look ahead to what’s next.
Go to page
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430
EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
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
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
NEWS
Read all
Partnership NICs: experts warn of danger to LLP model
HMRC manual changes: 31 October 2025
Mandatory director identity verification brought into force
Single supervisor for anti-money laundering
HMRC to raise awareness of MTD
CASES
Read all
Illuminate Skin Clinics Ltd v HMRC
Eurocent (Buckingham) Ltd v HMRC
Tyler Security Ltd v HMRC
Other cases that caught our eye: 31 October 2025
Lands Luo Ltd v HMRC
IN BRIEF
Read all
‘Partnership NICs’: the impact on the asset management sector
Time to bring back Budget purdah?
Transfer pricing ‘high-value’ intragroup services
Autumn Budget 2025: what tax measures can we expect?
Taking cover
MOST READ
Read all
Autumn Budget 2025: what tax measures can we expect?
HMRC manual changes: 17 October 2025
Management expenses: HMRC’s new nudge campaign
Tyler Security Ltd v HMRC
‘Partnership NICs’: the impact on the asset management sector