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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.
Private client review for January 2026
Sophie Dworetzsky
In this month’s update, Sophie Dworetzsky (Lombard Odier) reports the late change to the IHT reforms, the sharp increase in transparency and compliance obligations and some of the latest court rulings that matter.
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
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.
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.
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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
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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
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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