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ANALYSIS
Cutting edge analysis on tax issues.
International review for June 2023
Tim Sarson
Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
Hindsight is a wonderful thing but where MTD is concerned, it is not too late to learn from what the recent NAO report reveals, writes Paul Aplin OBE.
Withholding tax: Hargreave-ances
Deepesh Upadhyay
Sean Wright
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
Bhaur: mistake cannot unwind artificial avoidance scheme
Michael Avient
The Court of Appeal judgment in
Bhaur
provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
What happens at a tribunal hearing?
Anne Redston
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
Schedule 36: a stitch in time
Keith Gordon
There is nothing wrong with taxpayers insisting on their legal rights when faced with an HMRC information notice, writes barrister Keith Gordon (Temple Tax Chambers).
The umbrella company consultation: tackling non-compliance
Rebecca Seeley Harris
Rebecca Seeley Harris (Re Legal Consulting) has been campaigning for the regulation of the umbrella company industry and the protection of the worker, under the #FairUmbrella campaign since 2021. Here, she reviews the options for policy change set out in the recent umbrella company consultation.
Private client review for June 2023
Edward Reed
Andrew Crozier
Recent cases on information notices, penalties, and what is and is not a ‘mistake’ are reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
International aspects of demergers
Chris Holmes
Ross Robertson
Chris Holmes and Ross Robertson (BDO) explain how international aspects can complicate demergers and what tax issues to look out for.
The smoke and mirrors of tax avoidance
Tom Wallace
It is important to look at any tax planning arrangement in the round and not simply the marketing material, Tom Wallace (WTT Consulting) explains.
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430
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