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ANALYSIS
Cutting edge analysis on tax issues.
Revisiting the boilerplate withholding tax clause via 1962 (and beyond)
Ceinwen Rees
Serene Ho
Ceinwen Rees and Serene Ho (Kirkland & Ellis) explain why boilerplate
clauses exist and why it’s important to check that they are included in
the contract.
The new Labour government: challenges and opportunities
Bezhan Salehy
David Gauke
David Gauke and Bezhan Salehy (Macfarlanes) share their Treasury insights on
the practical challenges facing the new administration.
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
Scale to sale: tax considerations when selling a UK business
Liz Hunter
Nicola Simmons
Moustapha Hammoud
Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya)
explain the personal, employment and corporate tax issues.
Private client review for July 2024
Kazia Gagg
Edward Reed
Edward Reed and Kazia Gagg (Macfarlanes) consider what’s in store for
private clients under the new Labour government and comment on a number
of tribunal decisions on the remittance rules, SDLT and entrepreneurs’ relief.
The dirty dozen
James Quarmby
The 12 most annoying stereotypes about the world of tax, according to James Quarmby (Stephenson Harwood).
Beneficial ownership: practical applications
Helen Buchanan
Gabrielle Van der Haegen
Matthew Everett
Beneficial ownership and entitlement are pervasive concepts in tax law. Helen Buchanan, Matthew Everett and Gabrielle Van der Haegen (Freshfields Bruckhaus Deringer) explore some of the practical applications.
Tax and the City review for July 2024
Zoe Andrews
Mike Lane
The decisions in
JTI
,
Altrad
and
Burlington
are examined in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Summer 2024
Harry Smith
Adam Craggs
The principle of open justice is the overarching theme in this review by Adam Craggs and Harry Smith (RPC).
Disguised investment management fees: some international aspects
Robert Langston
Robert Langston (Saffery) explains why it is necessary to consider international tax principles, such as entity classification and transfer pricing, alongside the disguised investment management fee rules.
Go to page
of
453
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