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ANALYSIS
Cutting edge analysis on tax issues.
Modernising stamp duty: are we nearly there yet?
John Tolman
Emily Szasz
Emily Szasz and John Tolman (Freshfields Bruckhaus Deringer) examine the
proposals for a new UK stamp tax on securities regime.
Pillar Two: the consequences of staggered global implementation
Ashley Greenbank
Rhiannon Kinghall Were
While a coordinated roll-out of rules was once an aspiration, the reality is
anything but, explain Ashley Greenbank and Rhiannon Kinghall Were
(Macfarlanes).
Knocking on IRS’s door: the new accruals framework for carried interest
Linus Ostberg
Eli Hillman
Relief for double taxation of carried interest now needs to be found on
the other side of the Atlantic. The new accruals regime helps to make this
possible, write Eli Hillman and Linus Ostberg (KPMG).
International review for May 2023
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
The reserved investor fund regime: restricted or unrestricted, that is the question
Martin Shah
Martin Shah (Simmons
& Simmons) reviews the proposed reserved investor fund regime, while
Melville Rodrigues (Apex Group) says why it is needed.
The electricity generator levy: an introduction
Hiral Bhatt
Hiral Bhatt (Alvarez & Marsal) examines how the new levy will work and uncovers some uncertainties yet to be resolved.
HMRC consultation on the taxation of DeFi transactions
David Haworth
Alex Cheetham
HMRC has released a second consultation on the taxation of decentralised finance cryptoasset lending and staking transactions. David Haworth and Alex Cheetham (Freshfields Bruckhaus Deringer) review the proposals.
The UK’s international disclosure rules: where are we now?
Sharon Baynham
Sharon Baynham (KPMG) explains how the new reporting rules differ from DAC 6 and what action tax professionals should be taking.
Private client review for May 2023
Edward Reed
Tristan Honeyborne
The burden of proof as regards the taxpayer behaviour, late appeals and cautionary tales for IHT planning are among the topics featuring in this month’s review by Edward Reed and Tristan Honeyborne (Macfarlanes).
In conversation with... FTT President Greg Sinfield
Anthony Inglese
Anthony Inglese (former general counsel to HMRC) talks to Judge Sinfield, president of the FTT Tax Chamber, about his career and current work priorities.
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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