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ANALYSIS
Cutting edge analysis on tax issues.
HMRC v Part 26A: can you cram the Crown?
Abby Martin
Lisa Rickelton
Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
GE Financial, treaty residence, and the meaning of ‘business’
Kyle Rainsford
Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.
OECD pillar talk: Pillar Two looming; Pillar One a step closer
Brin Rajathurai
James Burton
Mitchell Fraser
Brin Rajathurai, James Burton and Mitchell Fraser (Allen & Overy) review last week’s OECD announcements on the two-pillar solution.
EU withholding tax: will things move FASTER?
Reinhart Devisscher
Paul Radcliffe
Ramzan Bashir
Current EU withholding tax procedures are costly, inefficient and prone to fraud. Is the Commission’s ‘FASTER’ proposal the answer? Paul Radcliffe, Reinhart Devisscher and Ramzan Bashir (EY) investigate.
How to handle R&D enquiries
Carrie Rutland
Helen Adams
Helen Adams and Carrie Rutland (BDO) provide a practical guide.
In conversation with... Dan Neidle of Tax Policy Associates
Anthony Inglese
Dan Neidle
Former HMRC general counsel Anthony Inglese talks to Dan Neidle about his high-profile retirement project.
Legislation day: draft Finance Bill 2024
A Lexis+ UK Tax report of the key announcements with additional practitioner comment.
A tougher approach at HMRC, but at what cost?
Ray McCann
Consultant and former CIOT president Ray McCann discusses the limitations of HMRC’s recent compliance strategy and suggests a more pragmatic approach.
Tax risk insurance: a practical guide
Ben Jones
Jannine Nicholas
Helen Mackey
Ben Jones, Helen Mackey and Jannine Nicholas (Eversheds Sutherland) explain how to obtain and maximise the benefits of tax risk insurance.
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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