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Consultation
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Consultation
CONSULTATION
Notification of uncertain tax treatments: round two
Gregory Price
Jack Slater
Gregory Price and Jack Slater (Macfarlanes) discuss the latest proposals
facing large businesses that require response by 1 June.
Finance Bill 2021: financial institution notices
Elena Rowlands
Ian Zeider
Despite criticism, financial institution notices look set to be introduced.
Elena Rowlands and Ian Zeider (Travers Smith) explore what this could
mean.
Transfer pricing: documentation proposals and disputes
Sarah Bond
Sarah Bond (Freshfields Bruckhaus Deringer) considers the implications for businesses of the proposed changes to required transfer pricing documentation currently under consultation.
The European Commission’s ‘digital levy’
Jennifer Maskell
Richard Sultman
The European Commission has a new ‘digital levy’ initiative, pending
international consensus on digital taxation. Jennifer Maskell and Richard
Sultman (Cleary Gottlieb Steen & Hamilton) consider how it might look.
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.
The economic crime levy: what’s proposed?
Gavin Helmer
Ali Kazimi
Ali Kazimi and Gavin Helmer (Hansuke) consider the nature of the economic crime levy consultation.
Taxation of credit funds: from one crisis to another
Lily Teh
Will Smith
Will Smith and Lily Teh (
White & Case) consider
some of the major trends and tax issues relevant to the establishment and operation of credit funds.
What exactly is a ‘security’?
Alistair Godwin
Alistair Godwin (
Grant Thornton)
focuses on the Taxes Acts in order to bring out some of the key features of a ‘security’ that are useful in practice.
The transfer pricing of financing transactions: OECD guidance
Andrew Stewart
Anton Hume
We are expecting new OECD guidance on the transfer pricing analysis of financing arrangements. Anton Hume and Andrew Stewart (BDO) consider what’s most likely to change.
Is the arm’s length principle dead?
Gary Richards
Robert Hartley
Gary Richards and Robert Hartley (Mishcon de Reya) focus on how OECD’s public consultation document on the ‘unified approach’ under pillar one sheds light on the future scope of the arm’s length principle.
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9
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
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455