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Capital allowances
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Capital allowances
CAPITAL-ALLOWANCES
The Orsted ‘tax nothing’
Andrew Page
Andrew Page OBE (formerly HMRC) argues that the denial of relief for
windfarm survey costs exposes a gap between the rules for capital allowances
and intangible assets.
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
Joe Williams
Tom Gardner
Emily Szasz
Jill Gatehouse, Emily Szasz, Joe Williams and Tom Gardner (Freshfields) examine HMRC’s proposed reforms to the taxation of distributions and their implications for capital returns, demergers and commercial transactions.
Permanent Establishment exemption: preparing for mandatory application
Lisa Shipley
Alison Lobb
Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory
foreign branch exemption means for UK businesses.
Legislation Day 2026: The consultation on predevelopment costs
Kim Ashley
Clarification rather than a fundamental expansion of relief?
How close is close enough? Orsted and the limits of ‘on the provision of plant’
Paul Farey
Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.
Budget 2025: the tax measures
A detailed report by Lexis®+ UK Tax, with additional practitioner insight.
Losses and major changes in the trade or business
John Angood
James Hewitt
John Angood and James Hewitt (BDO) provide a back to basics guide.
Capital allowances: uncertainty over design costs resolved by Court of Appeal
Paul Farey
Paul Farey (AECOM) assesses the impact of the Court of Appeal’s judgment
in
Gunfleet Sands
.
Perenco UK Ltd v HMRC
First-year capital allowances claim on oilfield plant and machinery allowed
Ten cases shaping tax practice in 2026
As 2026 passes its halfway point, we take stock of a busy year in the courts. From decisions on partnership tax and treaty abuse to VAT, inheritance tax planning to employment status, here is our pick of ten key cases shaping tax practice this year....
Go to page
of
7
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
HMRC name 196 deliberate tax defaulters
Loans to participators: s 455
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
One minute with... Tom Margesson
Modernising the taxation of distributions