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ANALYSIS
Cutting edge analysis on tax issues.
Emergency unravelling of the Growth Plan
Lexis
®PSL Tax and Private Client provide a
summary of the key tax announcements made in the chancellor’s emergency statement and subsequent speech delivered to the House of Commons, on 17 October 2022 which unravelled most of the measures announced in the Growth Plan (the ‘mini-Budget’) on 23 September 2022. With practitioner comment and an additional timeline of recent announcements.
Are EU state aid challenges by competitors always a ‘nuclear option’?
Paul Farmer
Simon Whitehead
Paul Farmer and Simon Whitehead (Joseph Hage Aaronson) consider how fiscal state aid issues should be addressed where the national tax provisions creating the aid are not based on a simple exemption from a standard rate but arise from differential rate regimes and asymmetric taxes.
Investment reliefs and the risk to capital condition: what do the first tribunal cases tell us?
Andrew Rainford
The tribunals appear keen to adopt an approach which is based in commercial reality, writes Andrew Rainford (Red Dragon Tax).
Private client review for October 2022
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) provide a round-up of the latest developments.
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Tax and the City review for October 2022
Zoe Andrews
Mike Lane
The decisions in
Burlington
and
Aozora GMAC
are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Register of overseas entities: a look back and ahead
Nick Lindsay
Dhruv Patel
Nick Lindsay and Dhruv Patel (Elemental CoSec) review the requirements of registration in advance of the 31 January deadline and highlight the issues that are proving challenging for the industry.
How to win reasonable excuse cases
A step-by-step guide for advisers, by Tolley®Guidance.
The Inflation Reduction Act 2022: less than promised?
Donald L Korb
Andrew Solomon
Donald L. Korb and Andrew Solomon (Sullivan & Cromwell) review the US legislation designed to support climate and health care initiatives, which contains three significant tax-raising provisions.
No gain, no pain: Sehgal and the remittance basis
Oliver Marre
Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
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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