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CORPORATE-TAX
International review for December 2025
Tim Sarson
Tim Sarson (KPMG) reports key international developments, led by the OECD’s
long-awaited guidance on permanent establishments for remote workers,
alongside major updates from Brazil, Canada, the EU and the CBAM regime.
Beyond the billions: how the 100 Group’s tax contribution reflects a broader corporate responsibility
David Gordon
The discussion about tax responsibility should go beyond the rate of tax
companies pay, writes David Gordon (100 Group Taxation Committee).
Ripe Ltd v HMRC
Licence of client list was an intangible fixed asset for CT purposes
AAA Oriental Ltd v HMRC
Sch 36 information notice upheld.
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
Other cases that caught our eye: 6 December 2024
Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...
R (oao Rettig Heating Group UK Ltd (in liquidation)) v HMRC
Upper Tribunal refuses application for disclosure in judicial review proceedings.
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Janet Bray Ltd v HMRC
Company was careless in implementing EBT scheme.
In conversation with... Steve Edge
Steve Edge
Anthony Inglese
Anthony Inglese CB talks to practitioner Steve Edge about his career and the changing world of tax.
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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
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress