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Crown preference
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Crown preference
CROWN-PREFERENCE
The resurgence of crown preference: the dog in the manger
Eloise Walker
Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).
HMRC v Part 26A: can you cram the Crown?
Abby Martin
Lisa Rickelton
Alex Lewis
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
The return of Crown preference
Eloise Walker
A failure to learn from history? Eloise Walker (Pinsent Masons) comments on a Budget measure concerning tax and insolvency.
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
HMRC to accept Advance Tax Certainty expressions of interest from 1 June
State Opening of Parliament 2026
IHT and pensions from April 2027: HMRC set out operational detail
TRF: clarification on trusts
GAAR Advisory Panel opinion
CASES
Read all
J Krason v HMRC
British Institute of Technology Ltd v HMRC
J Nuttall and another v HMRC
Other cases that caught our eye: 15 May 2026
Professional Game Match Officials Ltd v HMRC
IN BRIEF
Read all
Shinebrook: demolition is not construction
Madsen: discovery assessments
Protected foreign source income: limits exposed
Project Snowball
Online reporting for UK employee share plans and awards
MOST READ
Read all
Madsen: discovery assessments
Other cases that caught our eye: 8 May 2026
HMRC’s transfer pricing windfall: one-off or new normal?
M Parker v HMRC
Burlington: towards an international fiscal meaning of ‘main purpose’