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ANALYSIS

Cutting edge analysis on tax issues.

The OECD’s Pillar Two side-by-side package premium
Card image Lisa Shipley Alison Lobb Ed Wright
Alison Lobb, Lisa Shipley and Ed Wright (Deloitte) outline the Inclusive Framework’s much-awaited ‘side-by-side’ package.
14 January 2026
Complex statutory construction: the Court of Appeal’s approach in Tower One premium
Card image Helen Coward
Card image Cristy Ajediti
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
14 January 2026
Trouble in store for the Sehgals premium
Card image John Shallcross
John Shallcross (Blake Morgan) examines the counter-intuitive result in a mixed property SDLT decision.
14 January 2026
Tax and the City for January 2026 premium
Card image Zoe Andrews
Card image Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review Hotel La Tour, recent developments affecting the taxation of global mobility and HMRC’s new compliance guidelines on imported hybrid mismatches.
14 January 2026
Acting ‘as such’: the special legal regime after Northumbria Healthcare premium
Card image Denis Edwards
A recent Supreme Court judgment is now the starting point for identifying when a special legal regime exists, writes Denis Edwards (Temple Tax Chambers).
14 January 2026
HMRC’s priorities for 2026: building for the future premium
Card image Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy and Tax Design, outlines the department’s digital transformation plans, compliance strategy and modernisation agenda for the year ahead.
7 January 2026
Grandfathering premium
Card image John Barnett
The Government’s approach to APR and BPR reform combines delay and anti-forestalling in a way that risks serious unintended consequences, writes John Barnett (CIOT).
7 January 2026
Share reorganisations: new anti-avoidance rules explained starpremium
Card image Peter Morley
Card image Jamie Robson
The Autumn Budget 2025 tightens anti-avoidance rules for share reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain what tax professionals need to be aware of.
7 January 2026
Tax and the private capital sector in 2026: three key issues premium
Card image Elena Rowlands Ian Zeider Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) take stock of current developments.
7 January 2026
Direct and immediate links: the Supreme Court draws the line premium
Card image Dr Michael Taylor
Dr Michael Taylor (PwC) reviews the Supreme Court’s judgment in Hotel La Tour.
7 January 2026
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11 March 2026 / Peter Vaines
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