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ANALYSIS
Cutting edge analysis on tax issues.
When does the ratio of a judgment have no precedential value?
Michael Ridsdale
Gemma Williams
Exceptions to the doctrine of precedent do exist but, as a recent case
illustrates, they will be rarely applied in practice, write Michael Ridsdale and
Gemma Williams (Wedlake Bell).
Private client review for May 2024
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) review recent cases
concerning entrepreneurs’ relief, PPR and SDLT.
The taxation of carried interest: where are we now?
Ben Symons
The taxation of private equity executives has become highly politically contentious as we head into the next election. An Opposition policy costing document released in February this year (bit.ly/4dol4do) shows that the Labour Party plans to tax the...
Non-dom reform: the proposals
Rebecca Sheldon
Rebecca Sheldon (Old Square Tax Chambers) considers the proposals from the Conservative Party that give a broad indication as to how the new regime is intended to operate, and what might be expected if the Labour Party wins the General Election.
The post-election (anti-avoidance) enforcement landscape
Ross Birkbeck
With an estimated tax gap of some £36bn, Labour does seem to be taking enforcement seriously, writes Ross Birkbeck (Old Square Tax Chambers).
VAT, private school fees and anti-forestalling provisions: how far is too far (back)?
Shanzé Shah
Etienne Wong
Etienne Wong and Shanzé Shah (Old Square Tax Chambers) discuss the extent to which anti-forestalling legislation might challenge prepayments that attempt to preserve the existing VAT treatment of private school fees.
Wealth tax possibilities
Philip Simpson KC
It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).
When tax goes wrong
Michael Thomas KC
The position should be calmly evaluated at an early stage in order to put an
appropriate strategy in place, writes Michael Thomas KC (Pump Court
Tax Chambers). Easy to say in theory, but not always so easy to execute in
practice...
The Construction Industry Scheme and reg 20A: the incredible shrinking policy
Kyle Rainsford
The final CIS regulations and HMRC guidance don’t appear to measure up to the original policy ambition of removing ‘the majority of landlord to tenant payments from the scheme’, writes Kyle Rainsford (Travers Smith).
Tax and the City review for May 2024
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in
BlackRock
and
Hargreaves Property
, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.
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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