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Tax and the City review for November 2025
Zoe Andrews
Mike Lane
The latest developments that matter, reported by Mike Lane and
Zoe Andrews (Slaughter and May).
Management expenses: HMRC’s new nudge campaign
Constantine Christofi
Anna Lucey
HMRC’s nudge campaign signals a broader challenge to deductibility under
CTA 2009 s 1219, write Anna Lucey and Constantine Christofi (EY).
Close encounters with close companies (part 1): definitions and concepts
Ross McGregor
Hannah Manning
In the first of two articles examining the close companies rules, Hannah
Manning and Ross McGregor (Travers Smith) explain why it should not be
assumed that a company is not close without looking carefully at the relevant
legislation.
FA 2025 review: The loans to participators regime no more (re)paying your way
Hugh Gunson
With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The ‘loans to participators’ rules in...
Ask an expert: The BPR dilemma: IHT funding challenges for family-controlled businesses
Ellen Wildig
Sarah Ling
Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact
for family-controlled businesses of the upcoming reforms to business
property relief.
HMRC v Dolphin Drilling Ltd
Supreme Court ruling on oil contractor regime
Tax and the City review for May 2024
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May) examines the Court of Appeal decisions in
BlackRock
and
Hargreaves Property
, HMRC’s updated guidance on capital-raising arrangements and share exchange clearances, and the OECD’s consolidated commentary on the GloBE model rules.
HMRC v Dolphin Drilling Ltd
Court of Appeal rules that ‘hire cap’ under the oil contractor regime applied to restrict CT deduction.
CT deductions for cash cancelled or net-settled share options
Lorna Jordan
Alison Hughes
Welcome but with some caveats. Alison Hughes and Lorna Jordan (KPMG) review HMRC’s new guidance on this issue.
Royal Bank of Canada v HMRC
Double tax treaty did not confer UK taxing rights to oil royalty payments.
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of
2
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for December
HMRC manual changes: 12 December 2025
Finance Bill 2026 published
HMRC revise position on VAT grouping and the Skandia judgment
HMRC explain TOMS changes
CASES
Read all
Cases of 2025
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
Tax Journal's 2025 Budget coverage
TSI Instruments and import VAT recovery
Finance Bill 2026 published