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IN BRIEF
Views on recent developments in tax.
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tom Margesson
Elena Rowlands
Ian Zeider
Following on from an announcement in last years Budget, the Government has launched a consultation on making earlier ITSA payments. It envisages that having smaller, more frequent tax payments made closer to the time income is earned, will...
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
John Endacott
The current purchase of own share rules date from 1982 and are very restrictive. As a consequence, workarounds can be used to achieve capital treatment because income tax only applies to the return of value above the nominal value of the shares. This...
Foreign PE exemption becoming mandatory
Julia McCullagh
Ross Robertson
A shift to denying relief at the outset.
Solving the LLC double taxation problem
James McCredie
Andrew Crozier
A welcome consultation.
AI in R&D advisory: seven control points
AI’s value lies not in replacing professional judgement but in strengthening the evidence behind a defensible claim.
Information notices
Peter Vaines
The meaning of ‘reasonably required’.
Management rollovers and share-for-share exchange relief
HMRC provide some welcome comfort for private equity management rollovers.
Krason: careless conduct
Peter Vaines
Some helpful FTT guidance.
IHT replacement property relief restrictions
Andrew Marr
Can replacement property relief ‘bank’ historic BPR?
HMRC clarify CIS financing positions
Andrew McCarthy
Penny Simmons
HMRC have clarified their position after updated guidance raised uncertainty over construction funding arrangements.
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207
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC manual changes: 26 June 2026