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ANALYSIS
Cutting edge analysis on tax issues.
Contentious tax: 2023 mid-year review
Clara Boyd
Lauren Redhead
Emily Burke
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
PE funds and master holding companies: traps for the unwary
James Shorland
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
Beneficial entitlement in Hargreaves: is Indofood now part of UK domestic law?
Dominic Robertson
The Upper Tribunal in
Hargreaves
effectively seeks to import the Indofood concept of beneficial entitlement into domestic law. Dominic Robertson (Slaughter and May) examines the practical uncertainties this creates and questions whether the decision was correctly decided.
Incentivising fund managers: carried interest v growth shares
Kitty Swanson
Kirsten Hunt
Kitty Swanson and Kirsten Hunt (Mayer Brown) consider some key issues regarding incentivising fund managers in the context of the ongoing debate surrounding carried interest.
The VAT review for July 2023
Gary Barnett
Jo Crookshank
Jo Crookshank and Gary Barnett (Simmons & Simmons) cover a number of the latest developments in the VAT and indirect tax field.
In conversation with... Alan Evans, HMRC’s general counsel
Anthony Inglese
Former HMRC general counsel Anthony Inglese talks to Alan Evans, the current holder of that role, about his career and current work priorities.
Holding HMRC to a statement
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
20 questions on employee ownership trusts
Pete Miller
Nick Wright
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
Pillar Two: compatibility of the UTPR with double tax treaties
Bezhan Salehy
Sarah Ling
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Carried interest taxation: the European landscape
Ceinwen Rees
George Apps
Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.
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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
HMRC manual changes: 7 November 2025
Post Office Capture Redress Scheme tax exemptions
Chancellor seeks to reassure markets ahead of Budget
Welsh Government publishes second stage of Draft Budget
New regs pave way for delegation of HMRC PAYE functions
CASES
Read all
Northumbria Healthcare NHS Foundation Trust v HMRC
J Boulting v HMRC
HMRC v Ducas Ltd
Other cases that caught our eye: 7 November 2025
Illuminate Skin Clinics Ltd v HMRC
IN BRIEF
Read all
Exclusive purposes
‘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?
MOST READ
Read all
Tyler Security Ltd v HMRC
Time to bring back Budget purdah?
‘Partnership NICs’: the impact on the asset management sector
HMRC manual changes: 7 November 2025
Transfer pricing ‘high-value’ intragroup services