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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for April 2023
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide this month’s
round-up that includes Spring Finance Bill measures affecting financial
services.
Deliberate behaviour: what you need to know
Sophie Rhind
Is it true that what you don’t know can’t hurt you? Sophie Rhind
(Macfarlanes) examines recent cases considering the level of knowledge
sufficient for a finding that a taxpayer’s behaviour is ‘deliberate’.
Getting closure: the FTT’s approach in Hitchins
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine when the tribunal
will exercise its power to direct HMRC to issue a closure notice in light of the
recent case of
Hitchins.
Please pay on your way out: UK exit charges and Gallaher
Ben Elliott
With the litigation on UK exit charges seemingly set to continue, Ben Elliott
(Pump Court Tax Chambers) examines the impact of a recent CJEU decision.
Green tax incentives: an opportunity or a threat?
Silvana Van der Velde
Laura Hodgson
In terms of green tax incentives, the UK is lagging behind some other
jurisdictions, notably the US. Laura Hodgson and Silvana Van der Velde
(Travers Smith) consider how the UK should respond.
Is VAT due on the ‘free’ supply of digital platforms?
Valentina Sloane KC
News that the Italian authorities are assessing Meta for VAT on the supply of Facebook has thrown into the spotlight the issue of whether VAT is due on the supply of ‘free’ digital services. Valentina Sloane KC (Monckton Chambers) examines the issues at stake.
Characterising supplies for VAT following Mesto Zamberk
Michael Thomas KC
The characterisation test for VAT has received important clarification from the Court of Appeal, writes Michael Thomas KC (Pump Court Tax Chambers).
Brief 3/2023 and the special legal regime
Richard Woolich
Clara Boyd
Brief 3/2022
represents a success story for local authorities who will obtain a substantial VAT refund. Richard Woolich and Clara Boyd (DLA Piper) ask which other public bodies might be deserving of a sequel.
News Corp: let’s get digital
Giles Salmond
Rebekka Sandwell
Giles Salmond and Rebekka Sandwell (Eversheds Sutherland) consider the Supreme Court’s judgment in
News Corp v HMRC
.
The VAT review for April 2023
Bryn Reynolds
Gary Barnett
Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover a number of decisions which indicate the existence of a separate but parallel universe of VAT.
Go to page
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438
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