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ANALYSIS
Cutting edge analysis on tax issues.
Seeing the broader picture: HMRC’s information exchange powers and obligations
Mark Whitehouse
Miranda Edwards
Tax authorities have access to more sources of information than ever before. Mark Whitehouse and Miranda Edwards (PwC) explore recent developments in HMRC’s international and domestic information powers and consider the implications for multinationals.
HMRC’s assessment powers: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
Fishing and fishy? HMRC third party interviews in employment tax investigations
Christopher Kientzler
Christopher Kientzler (Fieldfisher) discusses issues around HMRC’s power to conduct interviews with workers in employment tax cases.
Privilege considerations in tax investigations
Clare Reeve Curatola
Kate Ison
Clare Reeve Curatola and Kate Ison (Bryan Cave Leighton Paisner) provide practical insight on maximising the protection of legal professional privilege.
A look into HMRC’s toolbox during a criminal investigation
Adam Craggs
Michelle Sloane
Adam Craggs and Michelle Sloane (RPC) explore the powers commonly deployed by HMRC during a criminal investigation.
The future of alternative dispute resolution in HMRC
Fiona McRobert
Fiona McRobert, Assistant Director of HMRC’s ADR Team, explains how the department is ‘looking to embed a resolution mindset’.
Tax and the City review for February 2024
Zoe Andrews
Mike Lane
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
The UK’s non-dom regime: the end of the road?
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys)
share their views on the current tax regime for UK resident non-domiciled
individuals and what might happen under a Labour government.
Incorporation relief and ESC D32: a myriad of uncertainty
Gordon W Buist
Gordon W Buist (EQ Accountants) explains how the publication of
Spotlight 63 on landlord tax planning schemes has exposed a fundamental
flaw with incorporation relief from CGT.
Capital allowances: buildings, structures or plant?
Paul Farey
Paul Farey (AECOM) considers the FTT’s ruling on the
Acorn Venture
case
and yet another discussion around what constitutes expenditure on plant.
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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