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Anti avoidance
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ANTI-AVOIDANCE
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
Budget 2025: Two things about corporation tax
Eloise Walker
When I originally suggested writing this comment piece, I thought I was going to be writing about exciting changes in partnership taxation, and various other interesting developments in the world of corporate tax. That all went out the window before...
Budget 2025: International private client tax issues
Lynnette Bober
Helen McGhee
There were several measures introduced by the 2025 Budget that will be of particular interest to HNW internationally mobile individuals, and I highlight a few of these below. £5m IHT cap for pre-October 2024 EPTs: There will be a £5m cap...
Budget 2025: the tax measures
A detailed report by Lexis®+ UK Tax, with additional practitioner insight.
Spring Statement 2025: report of the key tax announcements
A report by Lexis®+ UK Tax, with additional practitioner comment.
EIS disqualifying arrangements: jumping through the Hoopla
Tom Wilde
Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.
Other cases that caught our eye: 10 January 2025
Carried forward losses: In Blackfriars Hotel (UK) Holdings Ltd v HMRC [2024] UKFTT 1095 (TC) (6 December 2024), the FTT considered an appeal by the taxpayer against a decision of HMRC to deny the use of carried-forward non-trading loan relationship...
C Hoyle and others v HMRC
Sale of LLP capital accounts not subject to income tax.
R Grint v HMRC
Sale of occupation income tax charge
upheld.
New anti-avoidance legislation: the liquidation of LLPs
Victoria Braid
Gideon Sanitt
The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax bodies back Lords concerns over IHT reforms, including ‘huge’ burden on PRs
Finance Bill 2026 amendments
PAYE changes for employment expenses and gift aid relief
UK-Peru double tax convention
Welsh Budget
CASES
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Nimbus: The Disability Consultancy Service Ltd v HMRC
Delphi Derivatives Ltd (in liquidation) v HMRC
Other cases that caught our eye: 30 January 2026
HMRC v MedPro Healthcare
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
A Budget for its times? The Scottish Budget 2026/27
Case watch
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
Consultation tracker
HMRC manual changes: 23 January 2026