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ANALYSIS
Cutting edge analysis on tax issues.
SSE Generation: when is a tunnel a tunnel?
Will Scott
It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.
Etroy v Speechly Bircham: when do professional negligence claims become time-barred?
Anastasia Nourescu
Cécile Perrault
Advisers may face potential claims long after providing the initial advice, explain Anastasia Nourescu and Cécile Perrault (Stewarts).
Tax and the City review for June 2023
Mike Lane
Zoe Andrews
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider HMRC’s updated unallowable purpose guidance, an advocate general opinion on state aid challenges to tax rulings and an Upper Tribunal case which raises some interesting points on distributions and procedural fairness.
Judicial review: does the Court of Appeal’s decision in Murphy offer taxpayers a glimmer of hope?
Liam McKay
Adam Craggs
Judge on HMRC’s shoulder? A recent Court of Appeal ruling demonstrates that judicial review remains a vital and effective tool in defending taxpayers’ public law rights, write Adam Craggs and Liam McKay (RPC).
Back to basics: Section 260 holdover relief
Paul Townson
Sophie Mehta
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
HMRC’s approach to purpose-based enquiries
Sarah Bond
Helen Buchanan
Following a raft of recent case law, HMRC’s has revised its guidance on the unallowable purpose rules. Helen Buchanan and Sarah Bond (Freshfields Bruckhaus Deringer) consider what it says about HMRC’s approach to purpose-based enquiries and the situations which HMRC would normally regard as involving a tax avoidance purpose.
The first 100 days as a head of tax
Peter Mason
Although every head of tax role is different, there are many challenges and situations which are commonly encountered. In-house specialist Peter Mason and the Tax Director Network set out an approach for making a successful impact in the first 100 days.
The VAT review for June 2023
Gary Barnett
Bryn Reynolds
Bryn Reynolds and Gary Barnett (Simmons & Simmons) examine the latest developments affecting VAT, including two CJEU decisions and a significant change to the Retained EU Law Bill.
Modernising stamp duty: are we nearly there yet?
Emily Szasz
John Tolman
Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the
proposals for a new UK stamp tax on securities regime.
Pillar Two: the consequences of staggered global implementation
Rhiannon Kinghall Were
Ashley Greenbank
While a coordinated roll-out of rules was once an aspiration, the reality is
anything but, explain Ashley Greenbank and Rhiannon Kinghall Were
(Macfarlanes).
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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