Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Analysis
Home
Analysis
ANALYSIS
Cutting edge analysis on tax issues.
Ask an expert: Can HMRC override its own statutory review?
Constantine Christofi
Constantine Christofi (RPC) examines the legal and practical issues.
Ouroboros: VAT, HMRC, business, non-business
Etienne Wong
HMRC’s revised business test for VAT purposes oversimplifies the law
almost to the point of misrepresenting it, writes Etienne Wong (Old
Square Tax Chambers).
International review for October 2022
Tim Sarson
The OECD has been busy, as Tim Sarson (KPMG) explains.
Transfer pricing: a framework for implementing transactional profit split arrangements
Paul Sutton
Philip de Homont
Paul Sutton (LCN Legal) and Philip de Homont (Nera Economic
Consulting) set out a framework when considering the allocation of risks
in transfer pricing.
Are ‘provisions’ synonymous with ‘conditions’ in UK transfer pricing? A debate following BlackRock
Batanayi Katongera
Sarah Bond
Batanayi Katongera (in-house specialist) and Sarah Bond (Freshfields
Bruckhaus Deringer) discuss whether the UK terms should be given the
broader meaning of the OECD concepts in order to bring greater clarity
and reduce the risk of double taxation.
VAT on transfers of a business as a going concern
Marvin Reynolds
Lyndon Firth
Marvin Reynolds and Lyndon Firth (BDO) provide a refresher guide on
the tests for TOGCs for VAT purposes.
Big, bold, brash – and busted?
Chris Sanger
The new chancellor has reset expectations with an almost total reversal of his predecessor’s mini-Budget, writes Chris Sanger (EY).
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).
Go to page
of
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