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ANALYSIS
Cutting edge analysis on tax issues.
In conversation with... Alan Evans, HMRC’s general counsel
Anthony Inglese
Former HMRC general counsel Anthony Inglese talks to Alan Evans, the current holder of that role, about his career and current work priorities.
Holding HMRC to a statement
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) review two recent cases exploring the circumstances where a taxpayer can, and can’t, rely on a statement made by HMRC in order to establish a legitimate expectation.
20 questions on employee ownership trusts
Nick Wright
Pete Miller
Pete Miller and Nick Wright (Jerroms Miller) answer some of the key questions on this valuable regime.
Pillar Two: compatibility of the UTPR with double tax treaties
Bezhan Salehy
Sarah Ling
Bezhan Salehy and Sarah Ling (Macfarlanes) examine whether the Pillar Two undertaxed profits rule is susceptible to challenge under double tax agreements.
Carried interest taxation: the European landscape
Ceinwen Rees
George Apps
Ceinwen Rees and George Apps (Macfarlanes) compare the UK’s carried interest regime to European models.
International review for June 2023
Tim Sarson
Pillar Two is gathering further momentum with announcements this month from nine territories, reports Tim Sarson (KPMG).
Making Tax Digital: lessons from the NAO report
Paul Aplin OBE
Hindsight is a wonderful thing but where MTD is concerned, it is not too late to learn from what the recent NAO report reveals, writes Paul Aplin OBE.
Withholding tax: Hargreave-ances
Sean Wright
Deepesh Upadhyay
Deepesh Upadhyay and Sean Wright (Eversheds Sutherland) review the Upper Tribunal’s decision in Hargreaves which considers withholding tax and interest payments.
Bhaur: mistake cannot unwind artificial avoidance scheme
Michael Avient
The Court of Appeal judgment in
Bhaur
provides a salutary lesson to those considering artificial tax avoidance schemes, writes Michael Avient (Temple Tax Chambers).
What happens at a tribunal hearing?
Anne Redston
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
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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