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IN BRIEF
Views on recent developments in tax.
Incentivising the senior workforce
Chris Etherington
How employees over 55 could pay substantially less tax.
IR35 and Lineker v HMRC
Philip Swinburn
He thinks it’s all over; HMRC isn’t so sure.
Interest rates have soared but not for beneficial loans
Chris Etherington
An unexpected benefit.
Pension changes: what’s the impact on employee group life cover?
Excepted group life policies remain attractive despite removal of the lifetime allowance charge.
Lineker and the BBC
David Whiscombe
The notion that the IR35 rules are or are not capable of applying to a partnership depending on which partner signs the contract on behalf of the partnership is a surprising one - and will surely be appealed.
Practitioner view: Hybrid and other mismatch rules – double deduction issues
Matthew Mortimer
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Matthew Mortimer (Mayer Brown).
Practitioner view: The corporate interest expense restriction – risk allocation implications
Kitty Swanson
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Kitty Swanson (Mayer Brown).
Practitioner view: The rules recharacterising interest as a distribution – practical issues
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Catherine Richardson (Cadwalader, Wickersham & Taft).
Practitioner view: Unallowable purposes – ascertaining purpose
Comment on 'Practice guide: Restrictions on tax deductibility of loan interest' from Adam Blakemore (Cadwalader, Wickersham & Taft).
Transactions in securities: HMRC delays could cost it £34m
Chris Etherington
A freedom of information request highlights the extent to which HMRC has been enforcing the transactions in securities rules. The findings suggest an inconsistent approach by HMRC, with the average time for action to be taken potentially exceeding the permitted limits and over £34m of tax revenues at stake.
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197
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
Tax Journal authors for April 2025
HMRC manual changes: 2 May 2025
International tax rules back on the agenda
Mandatory payrolling of BIKs delayed
Update on LLP salaried member rules
CASES
Read all
C Candy v HMRC
G Quillan v HMRC
L-L-O Contracting Ltd and others v HMRC
Other cases that caught our eye: 2 May 2025
WTGIL Ltd v HMRC
IN BRIEF
Read all
PE and the investment management exemption
Changes to UK’s international tax regime
Tribunal intervenes in SDLT case
A statutory residence test bear-trap
Protected income and offshore income gains
MOST READ
Read all
VAT road fuel scale charges updated
Vaccine Research Limited Partnership and another v HMRC
WTGIL Ltd v HMRC
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
DST was always meant to be temporary, says Exchequer Secretary