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IPT
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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for April 2024
Zoe Andrews
Mike Lane
Recent decisions on intra-group VAT services, loan relationship debits and
distributions from non-UK resident company are examined by Mike Lane
and Zoe Andrews (Slaughter and May).
Prudential: members of VAT groups beware!
David Jamieson
David Jamieson (Baker McKenzie) provides an in-depth review of the Court
of Appeal judgment in
Prudential
and assesses the potential
fees are invoiced and paid after changes in VAT group membership.
The non-doms reforms: a practitioner view
Helen McGhee
Helen McGhee (Joseph Hage Aaronson) considers how practitioners should be advising clients during this uncertain time.
Mind the gap! Extension of the Transfer of Assets Abroad legislation post-Fisher
Emily Osborne
The Finance Bill measures have created more questions than answers, writes Emily Osborne (Stephenson Harwood).
Salaried LLP members: where are we now?
Jitendra Patel
LLPs would be well advised to consider the status of their members in light of recent developments, writes Jitendra Patel (BDO).
The VAT review for April 2024
Jo Crookshank
Gary Barnett
Pensions funds, Reemtsma claims and supplies by NHS trusts are among the topics in this month’s VAT review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
Contentious tax quarterly: Spring 2024 review
Harry Smith
Adam Craggs
We are seeing a flurry of activity from HMRC on DOTAS and on R&D claims, report Adam Craggs and Harry Smith (RPC).
Arguments before the Court of Appeal in BlackRock: is ‘just and reasonable’ a second bite of the cherry?
Neil Fletcher
Neil Fletcher (Alvarez & Marsal) discusses the implications of the decision for taxpayers where this is an obvious commercial purpose and a tax advantage.
Full proof: more needed from HMRC to discharge their burden of proof
Sophie Rhind
It is encouraging to see the FTT dealing robustly with situations where HMRC
fail to discharge their burden of proof, writes Sophie Rhind (Macfarlanes).
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
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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
Countrywide Partners Ltd v HMRC
Exceptional circumstances – but which way?
Tax agent registration and financial services
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker