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ANALYSIS
Cutting edge analysis on tax issues.
Transfer pricing: new guidance on hard to value intangibles
Vladimir Milic
Anton Hume
The guidance on HTVIs is likely to have a considerable impact on the development of transfer pricing compliance, write Vladimir Milic and Anton Hume (BDO).
International review for February 2022
Tim Sarson
Pillar one, UAE’s new federal corporate tax regime, and the Indian government’s Union Budget are among the recent developments examined
by Tim Sarson (KPMG).
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Ask an expert: SDLT, early possession and substantial performance
Simon Howley
Simon Howley (Bell Howley Perrotton) considers when a charge to SDLT
is triggered.
The VAT maze facing primary care networks
Jonathan Main
Primary care networks can present a confusing VAT picture, as
Jonathan Main (MHA Moore and Smalley) explains.
Private client review for February
Paige Achilles
Edward Reed
The latest key developments affecting private clients are reviewed by
Edward Reed and Paige Achilles (Macfarlanes).
Taxation of image rights: contracts and commerciality
Liesl Fichardt
Emily Au
When implementing image rights contracts, employers must make concerted
efforts to demonstrate the underlying commerciality of the arrangement by
monitoring ongoing activities, write Liesl Fichardt and Emily Au (Quinn
Emanuel Urquhart & Sullivan).
‘Am I a shell?’ The new question facing EU entities
Laura Hodgson
Laura Hodgson (Travers Smith) explains why the proposed new rules may
require businesses to bolster the substance of their EU holding companies.
Comment: Why we need a new disguised remuneration settlement opportunity
Sarah Gabbai
The government should take a more pragmatic approach to taxpayers affected by
the loan charge, writes Sarah Gabbai (McDermott Will & Emery).
Allam: a case full of interest
Lynnette Bober
Lynnette Bober (Gateley Legal) takes a closer look at a case involving
several diverse issues, not least the difficulties in overturning findings of fact
by the FTT.
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438
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
Joint ventures: applying ESC D33 in practice
P Kearney v HMRC
FS Commercial Ltd v HMRC