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ANALYSIS
Cutting edge analysis on tax issues.
IR35: spotting and responding to an HMRC enquiry
Penny Simmons
Steven Porter
Steven Porter and Penny Simmons (Pinsent Masons) provide guidance for
large businesses on managing IR35 compliance risks.
Sehgal and the application of the remittance basis
Oliver Marre
Just as we contemplate the demise of the remittance basis, Oliver Marre
(5 Stone Buildings) examines the first Upper Tribunal decision on a key
provision on those rules.
Dealing with HMRC information notices
Dan Williams
Adam Craggs
HMRC have formidable information gathering powers against which there
are limited rights of appeal. Adam Craggs and Dan Williams (RPC) look at
three common types of information notice and the extent to which they can
be challenged.
VAT on food: conflicting confections and deemed delicacies
Max Schofield
The Upper Tribunal in
Innovative Bites
has provided welcome clarity
on a contentious point of statutory construction, writes Max Schofield
(Devereux Chambers).
The VAT review for May 2024
Katie Oliver
Gary Barnett
Katie Oliver and Gary Barnett (Simmons & Simmons) examine this month’s
key VAT developments.
In conversation with... David Milne KC
David Milne KC
Anthony Inglese
Anthony Inglese CB talks to David Milne KC about life at the Tax Bar and
beyond.
More about the Loan Charge
David Pett
Jim Harra’s responses to specific questions asked by the Treasury Select Committee about the Loan Charge are, at least in part, a masterpiece in
Yes Minister
-style obfuscation, writes David Pett (Temple Tax Chambers).
Back to BlackRock: the Court of Appeal restores order
Helen Buchanan
Sarah Bond
The Court of Appeal judgment restores order, write Sarah Bond and
Helen Buchanan (Freshfields Bruckhaus Deringer).
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
International review for April 2024
Tim Sarson
The Advocate General’s opinion on the CFC Finco exemption state aid case,
new US regulations and an update on Pillar Two are among the developments
in this month’s review by Tim Sarson (KPMG).
Go to page
of
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