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ANALYSIS
Cutting edge analysis on tax issues.
Tax and the City for January 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review
Hotel La Tour
, recent developments affecting the taxation of global mobility and HMRC’s new compliance guidelines on imported hybrid mismatches.
Acting ‘as such’: the special legal regime after Northumbria Healthcare
Denis Edwards
A recent Supreme Court judgment is now the starting point for identifying when a special legal regime exists, writes Denis Edwards (Temple Tax Chambers).
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
Grandfathering
John Barnett
The Government’s approach to APR and BPR reform combines delay and
anti-forestalling in a way that risks serious unintended consequences,
writes John Barnett (CIOT).
Share reorganisations: new anti-avoidance rules explained
Peter Morley
Jamie Robson
The Autumn Budget 2025 tightens anti-avoidance rules for share
reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain
what tax professionals need to be aware of.
Tax and the private capital sector in 2026: three key issues
Elena Rowlands
Ian Zeider
Tom Margesson
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) take stock
of current developments.
Direct and immediate links: the Supreme Court draws the line
Dr Michael Taylor
Dr Michael Taylor (PwC) reviews the Supreme Court’s judgment in
Hotel La Tour
.
That was the year that was 2025
Zoe Andrews
Nadia Hourihan
Zoe Andrews and Nadia Hourihan (Slaughter and May) offer a whirlwind
review of 2025’s tax highlights and curiosities.
Comparing chancellors
Jeremy Mindell
Jeremy Mindell (Primondell) puts the current chancellor in historical context,
showing how past economic inheritances have shaped tax policy.
Tax in 2025: the good, the bad and the ugly
Heather Self
Heather Self (Blick Rothenberg) praises greater HMRC transparency while
warning of deepening fiscal drag and policy inconsistency.
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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
HMRC suggest SDLT payments may trigger adviser registration rules
NIC (Employer Pensions Contributions) Act receives royal assent
CIOT raises concerns over large business compliance burden
Commonwealth Games income tax regulations
CIOT calls for modernisation of treaty clearance process
CASES
Read all
Professional Game Match Officials Ltd v HMRC
M Parker v HMRC
T Kwok v HMRC
Other cases that caught our eye: 8 May 2026
HMRC v Burlington Loan Management DAC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Project Snowball
Transfer pricing changes: foreign exchange
HMRC issue Spotlight 63a on hybrid partnership property schemes
HMRC manual changes: 1 May 2026
Protected foreign source income: limits exposed