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IN BRIEF
Views on recent developments in tax.
BlueCrest: the impact for asset managers
The Supreme Court has made the salaried member rules harder to sidestep.
When Ramsay does not rescue HMRC
Eloise Walker
Section 59A means what it says.
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Elena Rowlands
Ian Zeider
Tom Margesson
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
Ross Robertson
Julia McCullagh
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.
Go to page
of
209
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
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
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Victoria Oil & Gas plc v HMRC
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Bolt: Supreme Court refuses permission to appeal
HMRC name 196 deliberate tax defaulters
One minute with... Tom Margesson