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ANALYSIS
Cutting edge analysis on tax issues.
QAHCs and UK securitisation companies: awkward bedfellows?
Matthew Durward-Thomas
Serena Lee
The QAHC regime seems a shinier, more flexible, version of the UK’s securitisation company regime. Serena Lee and Matthew Durward-Thomas (Akin Gump) consider how the two regimes interact.
Share deals: when is the optimum time to sell?
Laura Frenck
Lorna McCaa
Tax implications for sellers will often influence the optimum time to sell a company. Lorna McCaa and Laura Frenck (Dentons) address the main tax implications for UK corporate sellers and the related timing considerations.
Private client review for November 2022
Alice Mason
Edward Reed
A couple of further victories for HMRC on SDLT and a couple of victories for the taxpayer regarding information notices are among the developments reviewed by Edward Reed and Alice Mason (Macfarlanes).
Two wins for HMRC in DCM Optical Holdings narrow the scope of VAT challenges
Jake Landman
Abigail McGregor
The Supreme Court’s decision provides useful clarification on two issues arising in VAT disputes. Jake Landman and Abigail McGregor (Pinsent Masons) discuss the practical consequences for taxpayers.
Destination net zero: taxation of voluntary carbon credits
Andrew Hedges
Oliver Pendred
Companies are increasingly turning to voluntary carbon credits to achieve their decarbonisation objectives on the path to ‘net zero’. Oliver Pendred and Andrew Hedges (Baker McKenzie) explain the use and taxation of such credits for UK companies.
The Retained EU Law Bill: what you need to know
George Peretz KC
The Bill had its second reading in the House of Commons on 25 October. George Peretz KC (Monckton Chambers) looks at what it does and its implications for tax practitioners.
UK v Commission: the General Court’s critical error
Simon Whitehead
Did the General Court place too much emphasis on legislative technique and too little on substance and effect? Simon Whitehead (Joseph Hage Aaronson) critiques the state aid decision in
UK and ITV v Commission.
Tax and the City review for November 2022
Zoe Andrews
Mike Lane
This month’s round-up, by Mike Lane and Zoe Andrews (Slaughter and May).
Time to reconsider CSOP options?
Claire Matthews
New CSOP option reforms have seemingly escaped the mini-Budget cutting room floor. Claire Matthews (Taylor Wessing) explores the benefits.
Minimising the depletion of ‘clean capital’ by remittance basis users
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys) examine possible planning opportunities to safeguard a remittance basis user’s existing clean capital reserves.
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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
Tax agent registration and financial services
Countrywide Partners Ltd v HMRC
Exceptional circumstances – but which way?
Muller UK and Ireland Group LLP and others v HMRC
J Hosking v HMRC