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
Ask an expert
Home
Ask an expert
ASK AN EXPERT
Ask an expert: LLP to company - navigating incorporation relief
Claire Miles
QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...
Ask an expert: EMI v CSOP options post-April 2026
Veronika Lipinska
Matthew Emms
Matthew Emms and Veronika Lipinska (BDO) consider whether, following
the 2025 Budget reforms, a CSOP should now revert to EMI, and in what
circumstances CSOP or unapproved options might still be relevant.
Ask an expert: Buy now, pay later: deferred consideration in share sales
Dulcie Daly
Dulcie Daly (Goodwin) considers the complexities that can arise for
taxpayers when share sale proceeds include deferred amounts.
Ask an expert: EOTs v MBOs
Paul Townson
James Flint
Paul Townson and James Flint (BDO) consider whether a sale to an EOT is still the best route for a potential future sale of a privately owned trading business.
Ask an expert: Image rights, offshore structures and UK tax exposure
Sarah Richards
Sarah Richards (Sedulo Tax Advisory) explains why establishing a UAE image rights structure does not in itself remove UK tax exposure.
Ask an expert: The ‘dog-leg’: a way to fund non-dom divorces while preserving clean capital?
Henry Lowe
Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment
now that the non-dom regime has been abolished.
Ask an expert: The BPR dilemma: IHT funding challenges for family-controlled businesses
Ellen Wildig
Sarah Ling
Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact
for family-controlled businesses of the upcoming reforms to business
property relief.
Ask an expert: Just how enforceable is UK inheritance tax abroad?
Alyssa Haggarty
Claire Weeks
Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the
status of the so-called ‘revenue rule’ and the options available to HMRC to
seek assistance in the collection of tax abroad.
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Ask an expert: A case study on de-enveloping
Marc Selby
If a property is to be de-enveloped, the tax implications should be considered holistically and all the relevant taxes should be addressed. Marc Selby (Laytons) explains how the transaction should be structured.
Go to page
of
28
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
Tax Journal authors for April
HMRC issue Spotlight 63a on hybrid partnership property schemes
Government confirms that no SDLT charge for tenants on periodic tenancies
Unclaimed child trust funds
PIP awards: power to extend fixed-term awards introduced
CASES
Read all
HMRC v Burlington Loan Management DAC
HMRC v MR Currell Ltd
R Madsen v HMRC
Other cases that caught our eye: 1 May 2026
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
IN BRIEF
Read all
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
MOST READ
Read all
Centrica Energy Storage Ltd v HMRC
UK short-term business visitors: the Appendix 4 report
Clearwater Hampers Ltd v HMRC
Mega Marshmallows and the meaning of ‘normally’
HMRC issue updated VAT road fuel scale charges