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DPT
Groups
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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
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
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HMRC Powers
Investigations
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Issue 1695
Home
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Issue 1695
Issue 1695
7 February, 2025
Analysis
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
ScottishPower and the limits of von Glehn
Introducing CenTax: a new tax research centre
Map making
The VAT review for February 2025
In brief
Themes in UK corporate tax disputes for 2025 (and beyond)
JVs and the top-up taxes: does HMRC’s draft guidance bring clarity?
Reflections on the Budget fallout – three months on
News
HMRC manual changes: 7 February 2025
US ‘rejects very nature’ of UN tax talks
HMRC consulting on MTT and DTT draft guidance
HMRC data-collection powers
Retained EU law: further changes
CIOT urges Government to rethink IHT pensions proposals
UK suspends Russia and Belarus Double Tax Treaties
Finance Bill progress
New nudge letter on ATED avoidance qualifying property business relief
Basis period reform and late filing penalties
Updated HMRC guidance on MTD
Cases
M Ashley v HMRC
AAA Oriental Ltd v HMRC
Other cases that caught our eye: 7 February 2025
One minute with
One minute with... Richard Vallat KC
Trackers
HMRC manual changes: 7 February 2025
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC to accept Advance Tax Certainty expressions of interest from 1 June
State Opening of Parliament 2026
IHT and pensions from April 2027: HMRC set out operational detail
TRF: clarification on trusts
GAAR Advisory Panel opinion
CASES
Read all
J Krason v HMRC
British Institute of Technology Ltd v HMRC
J Nuttall and another v HMRC
Other cases that caught our eye: 15 May 2026
Professional Game Match Officials Ltd v HMRC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Madsen: discovery assessments
Other cases that caught our eye: 8 May 2026
HMRC’s transfer pricing windfall: one-off or new normal?
M Parker v HMRC
Burlington: towards an international fiscal meaning of ‘main purpose’