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IPT
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CFCs
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ANALYSIS
Cutting edge analysis on tax issues.
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.
Private client review for July 2023
Nisha Majumdar
Edward Reed
Edward Reed and Nisha Majumdar (Macfarlanes) review recent cases on reasonable excuse, HMRC fishing expeditions and the SDLT mixed-use rate.
Due diligence on acquisitions of UK REITs
Rob Williams
Rob Williams (FTI Consulting) reviews the dangers of not getting it REIT.
Why we’ve revised COP 9: the view from HMRC
Zoe Gascoyne
Zoe Gascoyne (HMRC) explains the importance of understanding the revised COP 9 and the contractual disclosure facility offer made as part of the process.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
Requirement to file CIS nil returns
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker