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APR
Private client review for April 2026
Sophie Dworetzsky
Sophie Dworetzsky (Lombard Odier) reviews recent developments including
rejected calls to extend IHT payment deadlines, proposed expansion of
the UTT regime to individuals and trusts, and practical issues arising from
pensions, SDLT and trust changes.
Finance Act 2026
Ros Martin
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Gifting APR/BPR assets on death
Simon Douglas
Simon Douglas (5 Stone Buildings) considers the will-drafting consequences of the new £2.5m allowance and its transferability – and explains why traditional ‘100% relief’ clauses may now not always achieve the desired result.
Grandfathering
John Barnett
The Government’s approach to APR and BPR reform combines delay and
anti-forestalling in a way that risks serious unintended consequences,
writes John Barnett (CIOT).
APR/BPR reform: a practitioner’s story
Stuart Maggs
This year has been a roller-coaster, writes Stuart Maggs (Howes Percival).
Budget 2025: International private client tax issues
Helen McGhee
Lynnette Bober
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.
BPR/APR changes in relation to relevant property trusts: planning points
Helen Lewis
Helen Lewis (Tolley) considers what planning can be undertaken to maximise
the relief available now and in the future.
No relief for reliefs: BPR and APR changes
Andrew Kerr
Emma Heelis-Adams
The draft legislation capping 100% BPR and APR has been published.
Emma Heelis-Adams and Andrew Kerr (Burges Salmon) explore the details.
Legislation day 2025: The APR and BPR reforms: sobering reading
Stuart Maggs
The Government might have consulted but it hasn’t listened.
Go to page
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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
Tax Journal authors for April
HMRC issue Spotlight 63a on hybrid partnership property schemes
Government confirms that no SDLT charge for tenants on periodic tenancies
Unclaimed child trust funds
PIP awards: power to extend fixed-term awards introduced
CASES
Read all
HMRC v Burlington Loan Management DAC
HMRC v MR Currell Ltd
R Madsen v HMRC
Other cases that caught our eye: 1 May 2026
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
IN BRIEF
Read all
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
MOST READ
Read all
Centrica Energy Storage Ltd v HMRC
UK short-term business visitors: the Appendix 4 report
Clearwater Hampers Ltd v HMRC
Mega Marshmallows and the meaning of ‘normally’
Uncertain tax treatments consultation: extending uncertainty?