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IPT
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Residence
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Withholding taxes
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Issue 1644
Home
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Issue 1644
Issue 1644
8 December, 2023
Analysis
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
New R&D scheme misses the point
Capital allowances: a question of design?
How to handle transfer pricing discovery assessments
The illusion of choice: the CIS in the DRC
Single supply and VAT exemption for financial services: insights from JPMorgan
Tax on funding family offices
Unlawful distributions: why knowledge matters
In brief
Schemes for landlords: a potential remedy?
Who owns goodwill?
News
HMRC manual changes: 8 December 2023
Tax burden on the rise for UK’s largest companies
HMRC issues new IR35 guidance
NIC bill progress
Format for DIY builder’s scheme claims
Update to VAT notice 700/12
Full customs controls from 31 January 2024
UK-New Zealand tax treaty dispute resolution arrangements published
Money laundering high-risk list updated
Majority of businesses accept indirect tax risk
DST checks for one third of tech giants
Phase two trial of the Wealthy Compliance Portal
Pension Schemes Newsletter 154
Cases
Atholl House Productions Ltd v HMRC
Acorn Venture Ltd v HMRC
Newcastle United Football Company Ltd v HMRC
Other cases that caught our eye: 8 December 2023
One minute with
One minute with... Alex Jupp
Trackers
HMRC manual changes: 8 December 2023
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’