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CGT
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Uncertain tax treatments consultation: extending uncertainty?
Yousuf Chughtai
Jack Prytherch
Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans
to widen the UTT regime and the practical implications for taxpayers.
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
FA 2025 review: Double remittances
Peter Vaines
Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...
Tax on SMEs in 2024
Andrew Constable
While 2024 has not exactly been plain sailing for SMEs, the tax related developments have not been as radical or fundamental as might have been feared, writes Andrew Constable (Mercer & Hole).
Other cases that caught our eye: 22 November 2024
Tax advantage to remuneration arrangements: FA 2022 gives HMRC the power to publish information where (broadly) it suspects that the main benefit of arrangements is to obtain a tax advantage. In K (oao Payeworx Ltd) v HMRC [2024] EWHC 2842 (Admin)...
Structuring following the new rules for IHT business and agricultural property reliefs
Michael Thomas KC
Diversifying ownership will become an increasingly important strategy in
light of the new restrictions to APR and BPR, writes Michael Thomas KC
(Pump Court Tax Chambers).
Partnerships and SP D12
Alex Sim
Tanja Velling
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Scale to sale: tax considerations when selling a UK business
Nicola Simmons
Moustapha Hammoud
Liz Hunter
Liz Hunter, Nicola Simmons and Moustapha Hammoud (Mishcon de Reya)
explain the personal, employment and corporate tax issues.
J Wardle v HMRC
Entrepreneurs’ relief claim allowed.
Selling an EOT-owned company: when can it be done and what are the consequences?
David Pett
David Pett (Temple Tax Chambers) discusses the trustee’s duties to consider
what is in the best interests of the beneficiaries as a class, how the sale
proceeds are to be distributed and the tax consequences of any sale.
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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
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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