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Issue 1727
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Issue 1727
Issue 1727
17 October, 2025
Analysis
Medpro: better late than never
How AI could change the interpretation of public CbCR data
Fraud: the next ‘failure to prevent’ frontier
Private client review for October 2025
OBBBA: one big beautiful guide for non-US tax professionals
In brief
Taking cover
More on s 455
HMRC’s technical note on RIFs
News
HMRC manual changes: 17 October 2025
Reeves should ‘grasp the nettle’ on tax reform, says IFS
HMRC raise game on football clubs
Conservatives would scrap SDLT, says Badenoch
Tax treatment of cryptoasset exchange traded notes
Trusts & estates return: practical point
Irish Budget 2026
Scottish Budget date now confirmed
Draft Welsh Budget
Cases
Mainpay Ltd v HMRC
Dialog Semiconductor Ltd v HMRC
Hippodrome Casino Ltd v HMRC
Other cases that caught our eye: 17 October 2025
One minute with
One minute with… Sam Brodsky
Trackers
HMRC manual changes: 17 October 2025
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
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
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
Management rollovers and share-for-share exchange relief
Consultation tracker
Solving the LLC double taxation problem
Sintra, Hall and the reshaping of HMRC’s burden of proof
The UK’s tax certainty problem
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