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Anti avoidance
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Anti avoidance
ANTI-AVOIDANCE
Certainty vs deterrence: the Supreme Court’s approach to anti-avoidance legislation in Fisher
Ben Elliott
The Supreme Court has effectively left it open to future courts to counteract artificial avoidance, writes Ben Elliott (Pump Court Tax Chambers).
SDLT and partnerships
Adam Kay
Susan Dennis
The SDLT partnerships rules are complex, with many areas of uncertainty. Adam Kay and Susan Dennis (Saffery) review some of the traps to be aware of.
HMRC v Delinian Ltd (formerly Euromoney Institutional Investment plc)
Court of Appeal confirms share exchange anti-avoidance rule did not apply.
The saga continues: implementing Pillar Two in the UK
Chris Sanger
Jack Gifford
The UK’s approach may require taxpayers to take a leap of faith that the final legislation will align with the GloBE rules, write Chris Sanger and
Jack Gifford (EY).
The first year allowance (or full expensing)
Andrew Green
Lawrence Wild
Andrew Green and Lawrence Wild (FTI Consulting) discuss the latest
temporary investment incentives.
The VAT review for April 2023
Gary Barnett
Bryn Reynolds
Gary Barnett and Bryn Reynolds (Simmons & Simmons) cover a number of decisions which indicate the existence of a separate but parallel universe of VAT.
Back to basics: SDLT and partnerships
Anisha Polson
Paul Beausang
Paul Beausang and Anisha Polson (Eversheds Sutherland) provide a
refresher guide to what must be among the most complex of all the SDLT
rules.
Debt restructuring: deemed releases
Paul Pritchard
The impact of the pandemic may necessitate a financial restructuring of a company’s liabilities. Paul Pritchard (FTI Consulting) provides a practical guide to the tax issues surrounding deemed release rules.
The UK asset holding company regime: what’s proposed
Elena Rowlands
Cathryn Vanderspar
Ian Zeider
Elena Rowlands, Cathryn Vanderspar and Ian Zeider (Travers Smith) are hopeful that the government will seize the opportunity for positive change to support the UK’s funds industry.
The consultation on VAT grouping
Daniel Johnson
Chris Chatting
Daniel Johnson and Chris Chatting (Deloitte) consider why this issue has
been raised now and what the future changes might be.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime