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AI: the answer to the data challenge in tax investigations
Sara Sinfield
Beth Sercombe
Sara Sinfield and Beth Sercombe (Ashurst Perkins Coie) explore how AI can
transform document review in tax investigations, highlighting the efficiency
gains, practical limitations and importance of expert supervision.
AI in tax disputes: risks and routes of challenge
Liesl Fichardt
Emily Au
Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in
tax disputes and the implications for transparency, fairness and taxpayer
challenges.
Contentious tax quarterly: Spring 2026
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) review recent decisions on costs for unreasonable behaviour, the use of AI in litigation and the scope of the FTT’s jurisdiction, as well as increased HMRC criminal investigations into advisers.
Private client review for March 2026
Sophie Dworetzsky
From AI in court to IHT and judicial review, Sophie Dworetzsky
(Lombard Odier) reviews the latest developments.
How AI can help democratise tax administration
Stephen Daly
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
Private client review for February 2026
Sophie Dworetzsky
Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
R&D tax in 2025: the calm after the storm?
Jenny Tragner
Jennifer Tragner (S&W) considers an unsettled year for R&D reliefs, where
transitional rules, evolving guidance and emerging AI questions kept advisers
busy despite few new policy changes.
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
A year at the Tax Bar in 2025
David Yates
David Yates KC (Pump Court Tax Chambers) reflects on a year marked by
unpredictable litigation, shifting private client rules and the evolving realities
of practice at the Tax Bar.
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EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455