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ANALYSIS
Cutting edge analysis on tax issues.
VAT and TOGCs: lessons from Haymarket
Jonathan de Wilton
Can the sale of a development site marketed with vacant possession meet the
conditions for a VAT free TOGC when the purchaser suggests setting up leases
with friendly parties? Jonathan de Wilton (Grant Thornton) investigates.
International review for June 2022
Tim Sarson
Delay and a lack of political consensus on BEPS feature in this month’s review
by Tim Sarson (KPMG).
The statutory residence test: an exceptionally useful case on ‘exceptional circumstances’
Catrin Harrison
Dominic Lawrance
Dominic Lawrance & Catrin Harrison (Charles Russell Speechlys) examine the first reported judgment which makes it clear that the relief is there to prevent injustices arising from the prescriptive nature of the statutory residence test.
Back to basics on pensions lifetime allowance
Chris Holmes
Catherine Morgan
Chris Holmes (BDO) and Catherine Morgan (Consilio Consulting) provide a refresher on the workings of this allowance.
Private client review for June 2022
Andrew Crozier
Edward Reed
Decisions on the validity of discovery assessments and information notices are among the recent developments reviewed by Edward Reed and Andrew Crozier (Macfarlanes).
The super-deduction and SR allowance: claims on construction projects
Paul Farey
Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim.
When careful taxpayers make mistakes
Claire Miles
If a lack of reasonable care is being alleged, it is essential to understand the taxpayer’s mindset when the mistake was made, as well as any steps the taxpayer took to file their return correctly, writes Claire Miles (Willkie Farr & Gallagher).
The VAT review for June 2022
Gary Barnett
This month’s review by Gary Barnett (Simmons & Simmons) covers an important advocate general’s opinion.
Tax and the City review for June 2022
Zoe Andrews
Mike Lane
The latest developments that matter, reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Mainly ignored? The main purpose test for SDLT group relief
Helen Coward
Helen Coward (Charles Russell Speechlys) examines the decision in
The Tower One St George Wharf Ltd
concerning the SDLT group relief
anti-avoidance rule.
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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
Exceptional circumstances – but which way?
Tax agent registration and financial services
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
J Hosking v HMRC