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DPT
Groups
Transactional tax
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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
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SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
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Home
Issue
1374
Home
Issue
1374
Issue 1374
20 October, 2017
Analysis
How to handle the new corporate interest restriction
The new directive on tax dispute resolution mechanisms
How big is the transfer pricing prize for developing countries?
International briefing for October 2017
In brief
Balhousie: interpreting a tax statute
The CJEU ruling in Mercedes-Benz
Pensions myth-busting: overseas transfers
News
HMRC using DPT to boost transfer pricing enquiries
Code of practice on taxation for banks annual report
ATT proposes amendment to trading allowance
Money laundering supervision fees increase
Fulfilment house due diligence scheme
HMRC's trust registration service goes live for agents
OECD publishes guidance on cross-border VAT collection
HMRC’s use of deeds to settle tax enquiries: legal implications
Draft guidance on penalties for enablers
HMRC’s payment methods are changing
Finance Bill progress
New HMRC guidance
Cases
Clavis Liberty Fund 1 LP v HMRC
Air Berlin v HMRC
Inventive Tax Strategies and others v HMRC
Inventive Tax Strategies and others v HMRC
S Rasul v HMRC
M Hafeez Katib v HMRC
One minute with
One minute with... Vanessa Houlder
Ask an expert
Waiver of inter-company debt between group companies
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
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
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
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’