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CROSS-BORDER
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
Jivaan Bennett
Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
FASTER: a European Withholding Tax Directive
Paul Radcliffe
Reinhart Devisscher
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
The VAT review for November 2023
Katie Oliver
Gary Barnett
This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers the Supreme Court decision in
Target Group
, the CJEU ruling on ‘free gift’ promotions, the potential use of split payments in the collection of VAT and the draft legislation intended to ensure stability on the interpretation of VAT and excise laws.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Philip Baker KC
Dilpreet K. Dhanoa
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
DAC 6 update: UK narrows scope of mandatory reporting
Avi Kaye
Sandy Bhogal
Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.
Key issues for in-house tax teams: a checklist
Chris Holmes
Mark Ellis
James Egert
Chris Holmes, Mark Ellis and James Egert (BDO) set out important current corporate and employer tax issues which in-house tax teams should now be addressing.
HMRC’s final guidance on DAC 6: a good first attempt?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) discuss the published guidance that still leaves many key questions around the scope of DAC 6 reporting obligations.
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5
EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
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
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
NEWS
Read all
OECD issues Pillar Two review framework and revised GIR
VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
CASES
Read all
J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
Read all
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
MOST READ
Read all
Grand Smile Design Ltd v HMRC
Raising standards without regulating the profession
Consultation tracker
The Executors of Hunt and others v HMRC
HMRC manual changes: 4 September 2026