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ANALYSIS
Cutting edge analysis on tax issues.
Is tax competition dead? What factors do multinationals take into account?
Sarah Osprey
Weighing up the competitiveness of different jurisdictions from a corporate tax perspective requires a nuanced analysis. Sarah Osprey (Slaughter and May) sets out the key factors to consider and explains why, with tax, it is rare to find a jurisdiction that is a clear winner.
A careless chancellor
Heather Self
Heather Self (Blick Rothenberg) reviews the controversy surrounding Nadhim Zahawi’s tax affairs.
The taxation of settlement agreements: a new approach?
Joshua Carey
Marianne Tutin
Joshua Carey and Marianne Tutin (Devereux Chambers) discuss a recent tribunal decision that highlights why the tax treatment of sums paid under any settlement agreements must be considered carefully.
VAT in the digital age: the European Commission’s proposals
Nadav Shayovitz
Luigi Lungarella
The EU has introduced far-reaching legislation governing the digital reporting of transactions, write Luigi Lungarella and Nadav Shayovitz (PKF Littlejohn).
International review for January 2023
Tim Sarson
Tim Sarson (KPMG) provides a recap of recent Pillar One and Two developments, and looks ahead to what’s in store throughout 2023.
Timing of dividends for income tax purposes
Dominic Stuttaford
Aiden Hepworth
Two recent cases provide a reminder of the extent to which taxation outcomes can depend on other areas of law and demonstrate that HMRC will not be limited to ‘pure’ tax law arguments on appeal, write Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright).
Ridgway, SDLT and s 75A: HMRC giveth and taketh away
Patrick Cannon
Patrick Cannon (Cannon Chambers) examines a recent tribunal decision on self-assessed mixed-use SDLT and the broader issue of reliance on HMRC’s published guidance.
Victory – but at what cost?
Harry Smith
Adam Craggs
From a review of recent costs decisions, it is difficult to escape the conclusion that the FTT can be guilty of inconsistency and results-led reasoning when exercising its jurisdiction in relation to costs orders, write Adam Craggs and Harry Smith (RPC).
Private client review for January 2023
Edward Reed
Andy Carruthers
A couple of taxpayer victories concerning the income tax treatment of dividends are among the developments reviewed by Edward Reed and
Andy Carruthers (Macfarlanes).
Deciphering the leaseholder: beating HMRC’s odd habit
Chris Nyland
HMRC has extended its losing streak against law firms that take leases through a subsidiary company. Chris Nyland (Scammell & Nyland) explores why HMRC keeps attacking the same structure, and how better to ensure that it doesn’t win.
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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