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Issue 1678
Home
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Issue 1678
Issue 1678
20 September, 2024
Analysis
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Corporation tax rate complexities for corporate LLP members
Private client review for September 2024
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
In brief
A bad Apple ruling
Millionaire migration
The Supreme Court’s decision in PGMOL
News
HMRC manual changes: 20 September 2024
Business Tax Roadmap: stability is key, says CIOT
HMRC’s new transfer pricing guidelines ‘suggest more aggressive approach’
R&D information requirements revised
Fractional shares in ISAs to be allowed
CIOT seeks clarity on ‘ordinary share capital’
ATT highlights pitfalls of FHL abolition
Clarifications required on non-dom proposals
Delay VAT on school fees, says ATT
Zero-rating of caravans
HMRC expands MTT/DTT draft guidance
Judicial Review Guide published
HMRC interest rates require further review, suggests CIOT
New HMRC bank transfer details
Cases
European Commission v Ireland and others
HMRC v Professional Game Match Officials Ltd
Muller UK and Ireland Group LLP and others v HMRC
K McCabe v HMRC
Joined Cases
One minute with
One minute with... Jitendra Patel
Trackers
HMRC manual changes: 20 September 2024
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’