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Anti avoidance
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Anti avoidance
ANTI-AVOIDANCE
SDLT and partnerships
Susan Dennis
Adam Kay
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
Jack Gifford
Chris Sanger
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
Bryn Reynolds
Gary Barnett
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
Ian Zeider
Cathryn Vanderspar
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.
Legislation day highlights
Rhiannon Kinghall Were
Rhiannon Kinghall Were (Macfarlanes) examines the draft legislation and
other policy measures published this week.
Go to page
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8
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
Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker