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ANALYSIS
Cutting edge analysis on tax issues.
Private client review for October 2022
Klara Kronbergs
Edward Reed
Edward Reed and Klara Kronbergs (Macfarlanes) provide a round-up of the latest developments.
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Tax and the City review for October 2022
Zoe Andrews
Mike Lane
The decisions in
Burlington
and
Aozora GMAC
are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
Register of overseas entities: a look back and ahead
Nick Lindsay
Dhruv Patel
Nick Lindsay and Dhruv Patel (Elemental CoSec) review the requirements of registration in advance of the 31 January deadline and highlight the issues that are proving challenging for the industry.
How to win reasonable excuse cases
A step-by-step guide for advisers, by Tolley®Guidance.
The Inflation Reduction Act 2022: less than promised?
Donald L Korb
Andrew Solomon
Donald L. Korb and Andrew Solomon (Sullivan & Cromwell) review the US legislation designed to support climate and health care initiatives, which contains three significant tax-raising provisions.
No gain, no pain: Sehgal and the remittance basis
Oliver Marre
Oliver Marre (5 Stone Buildings) examines the FTT’s landmark decision that provides the first judicial treatment of some fundamental questions on the remittance basis code.
The VAT review for October 2022
Bryn Reynolds
Gary Barnett
Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover the latest domestic and EU developments.
Back to basics: Salaried LLP members
Jitendra Patel
Jitendra Patel (BDO) provides a guide to the salaried members rules that were introduced in 2014 to deal with ‘disguised employment’ of members of limited liability partnerships.
International review for September 2022
Tim Sarson
Tim Sarson (KPMG) reviews the international landscape, including renewed impetus to implement Pillar Two and the latest US tax developments.
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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