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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City review for March 2023
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent decisions of interest and the latest transfer pricing and diverted profits tax statistics.
Back to basics: Section 165 holdover relief
Paul Townson
Chris Holmes
Chris Holmes and Paul Townson (BDO) provide a back to basics guide on this valuable relief.
Earn-outs in M&A transactions: working hard for capital treatment?
Dominic Robertson
Tomás McGrath
Tomás McGrath and Dominic Robertson (Slaughter and May) discuss
pitfalls and practical tips when considering earn-outs in M&A transactions.
Ask an expert: Offshore trusts and trustee borrowing
Julie Howard
Julie Howard (Boodle Hatfield) considers the ways of funding distributions to beneficiaries from an offshore trust, some of whom are UK resident.
The VAT review for March 2023
Bryn Reynolds
Gary Barnett
In this month’s review, Gary Barnett and Bryn Reynolds (Simmons & Simmons) consider the impact of recent case decisions on input VAT for a fundraising transaction, the meaning of appealable decision and HMRC’s approach to evidence of export.
Tax, politics and the next general election
Heather Self
Heather Self (Blick Rothenberg) suggests what the main political parties should – and, importantly, should not – include in their manifestos.
Untangling the tax spaghetti bowl: a look back at the OTS
Bill Dodwell
Bill Dodwell (OTS) looks back at the work of the Office of Tax Simplification.
HMRC’s new ADR guidance: more harm than good?
Anastasia Nourescu
David Pickstone
Anastasia Nourescu and David Pickstone (Stewarts) consider the pitfalls of HMRC’s newly published ADR guidance and how taxpayers and advisers should approach ADR going forward.
Tax procedure’s dead parrot: staleness and stare decisis
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) reviews a recent decision of the Upper Tribunal on staleness and Supreme Court precedent.
How is HMRC using financial institution notices?
Jack Prytherch
Jack Prytherch (CMS) discusses the key updates from the first report on HMRC’s use of financial institution notices.
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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