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ANALYSIS
Cutting edge analysis on tax issues.
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.
Privileged documents and third party notices: how far do HMRC’s information powers reach?
Oliver Marre
Oliver Marre (5 Stone Buildings) examines an FTT decision that provides helpful commentary on the approach to be taken to privileged documents, proportionality and relevance.
Global Britain? Trade, customs and tax in 2023
Caroline Barraclough
Amanda Tickel
James Caldecourt
James Caldecourt, Amanda Tickel and Caroline Barraclough (Deloitte) discuss how the UK is implementing an independent trade policy against a backdrop of Brexit, Covid-19 and a global trading system under increasing strain.
International review for February 2023
Tim Sarson
The OECD’s much-awaited Pillar Two administrative guidance is among the recent developments reviewed by Tim Sarson (KPMG).
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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
Countrywide Partners Ltd v HMRC
Exceptional circumstances – but which way?
Muller UK and Ireland Group LLP and others v HMRC
Tax agent registration and financial services
J Hosking v HMRC