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IN BRIEF

Views on recent developments in tax.

Country by country reporting
The OECD updates its guidance.  
20 November 2019
Reader feedback: Have ordinary loans really become surprise hybrids?
Or can the problematic ‘50% investment’ test in TIOPA 2010 s 259ND(4) be interpreted so as to remove plain vanilla lenders from the control group test?
20 November 2019
IR35: a new approach for enquiries?
Card image Dawn Register
HMRC’s reassurance on retrospective IR35 enquiries is welcome, although it falls short of an absolute guarantee of protection. 
14 November 2019
Towards a global minimum corporate tax rate?
Examining the OECD’s ‘pillar two’ proposals.  
14 November 2019
Reader feedback: unitary taxation
A reader challenges last week’s ‘Self’s assessment’.  
14 November 2019
HMRC wins in Upper Tribunal on IR35
Card image Jeremy Edwards
Lessons on control from Ackroyd.  
 
7 November 2019
EU watch: quo vadis, public tax transparency?
Card image Johan Barros
The progress of the European Commission’s proposal for public country by country reporting depends on whether it is regarded primarily as a tax or a company law matter. 
4 November 2019
Self's assessment: will Labour make the tech giants pay their ‘fair share’?
Card image Heather Self
In our continuing series, Heather Self examines the tax headlines in the national media. This week, the Labour party’s proposed tax raid on the tech companies.
4 November 2019
Reliance on HMRC manuals
Card image Peter Vaines
It is difficult to see how the test for legitimate expectation set by the Court of Appeal could ever be met.
30 October 2019
The draft Withdrawal Agreement and the Irish backstop replacement
Card image Aurell Taussig
Card image Lode Van Den Hende
The key questions raised by the new Brexit deal’s Irish backstop replacement.
30 October 2019
EDITOR'S PICKstar
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J Boulting v HMRC
5 November 2025
HMRC v Ducas Ltd
5 November 2025
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Exclusive purposes
5 November 2025 / Peter Vaines
MOST READ Read all
Tyler Security Ltd v HMRC
29 October 2025
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