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ANALYSIS
Cutting edge analysis on tax issues.
Lead cases in the tax tribunal: the rule 18 procedure
Anastasia Nourescu
Matthew Greene
Matthew Greene and Anastasia Nourescu (Stewarts) explain what the rule 18 lead case procedure is, review recent case law clarifying its scope and set out a few practical tips for advisers.
The impact of Ablessio: HMRC’s power to deregister taxpayers
Joshua Carey
Howard Watkinson
For the first time the Upper Tribunal has considered the impact and scope of
the
Ablessio
abuse principle for deregistering a taxpayer from VAT.
Howard Watkinson and Joshua Carey (Devereux Chambers) examine
the judgment and its implications
.
VAT on payment services: off Target
Michael Ripley
Hui Ling McCarthy KC
Hui Ling McCarthy KC and Michael Ripley (11 New Square) examine
the much-awaited Supreme Court judgment on the VAT liability of loan
administration services.
Planning for the substantial shareholding exemption following M Group Holdings
Robert Langston
The obvious conclusion from the Upper Tribunal decision is that every
standalone company should form a dormant subsidiary, writes Robert Langston
(Saffery Champness), but there are anti-avoidance rules to consider.
The stamp taxes on shares modernisation: modern enough?
Richard Sultman
Peter North
While awaiting the outcome of HMRC’s consultation on stamp tax
modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider
some missed opportunities and unresolved issues.
International tax cooperation: the UN’s call for greater inclusivity and effectiveness
Sarah Blakelock
The UN is demanding a greater role in setting the global tax policy agenda,
but some countries have questioned whether this undermines the OECD/G20
Inclusive Framework discussions. Sarah Blakelock reports.
Tax and the City review for October 2023
Zoe Andrews
Mike Lane
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
CT deductions for cash cancelled or net-settled share options
Lorna Jordan
Alison Hughes
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Blurred lines: occupation, profession or vocation?
Liesl Fichardt
Emily Au
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
The VAT review for October 2023
Jo Crookshank
Gary Barnett
Hotel La Tour
,
Impact Contracting Solutions
and a CJEU decision on deducting overpaid VAT are in this month’s review by Jo Crookshank and Gary Barnett (Simmons & Simmons).
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
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
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC