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ANALYSIS
Cutting edge analysis on tax issues.
Spring Budget 2023: report
A detailed report by Tolley and LexisNexis®PSL Tax with additional practitioner comment.
Terminating an acquisition mid-completion
Eloise Walker
As contract terminations proliferate in uncertain economic times, Eloise Walker (Pinsent Masons) looks at the tax issues arising from terminating an acquisition before it completes.
Partnership tax disputes: referral to the FTT
David Whiscombe
Can it really be right that the taxability (or not) of a receipt can be determined by the partnership, with the recipient partner having no right to object? David Whiscombe (David Whiscombe LLP) discusses a tribunal decision that considered for the first time the scope of TMA 1970 s 12ABZB.
How binding are FTT decisions?
Oliver Marre
Oliver Marre (5 Stone Buildings) considers two ways in which decisions of the FTT can influence the results of later cases.
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.
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453
EDITOR'S PICK
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
1 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
2 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
3 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
4 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
5 /7
The new Securities Transfer Tax: business as usual?
Georgina West
6 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
7 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
NEWS
Read all
Tax receipts rise, but borrowing exceeds OBR forecast ahead of Budget
Construction industry scheme compliance
CIOT urges legislative change on pre-development costs
CIOT backs faster land remediation relief but warns on planning link
Only one in ten highest earners pay top tax rate, says CenTax
CASES
Read all
Environmental Services Ltd v HMRC
Sir J Griffin v HMRC
Minerva Research Labs Ltd v HMRC
Other cases that caught our eye: 25 September 2026
J Scheckter v HMRC
IN BRIEF
Read all
Substantial
Modernising the taxation of distributions: why now?
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
MOST READ
Read all
J Scheckter v HMRC
Consultation tracker
Sir J Griffin v HMRC
Redrawing the line: modernising the taxation of distributions
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5