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Private client review for October 2026
Sophie Dworetzsky
In this month’s review, Sophie Dworetzsky (Lombard Odier) reflects on potential changes to tax policymaking, landlord registration, HMRC’s scrutiny of cryptoassets and adviser conduct, and a recent domicile decision.
Employment-related securities: the fallout from Vermilion
David Pett
David Pett (Temple Tax Chambers) writes that the FTT in CooperVision has
‘muddied the waters’ and made it more difficult to advise on whether shares
are employment-related securities.
Contentious tax quarterly: Autumn 2026
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) review recent decisions on
unreasonable conduct, costs awards and protective costs orders, highlighting
the practical lessons for taxpayers and advisers.
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.
Private client review for September 2026
Sophie Dworetzsky
Sophie Dworetzsky (Lombard Odier) reflects on the run-up to the Budget and reviews developments on IHT on pensions, cryptoasset compliance and a recent case on corporate residence.
The new taxpayer duty to correct inaccuracies: an obligation lacking clear boundaries
Peter North
Rob Sharpe
An obligation to correct tax return inaccuracies is coming. Rob Sharpe and
Peter North (Cleary Gottlieb) examine the mechanics and some interpretative
uncertainties.
The VAT review for August 2026
Jo Crookshank
Gary Barnett
Jo Crookshank and Gary Barnett (Simmons & Simmons) review recent
VAT developments concerning education, one-off sales, taxi services, the
Capital Goods Scheme and online marketplaces.
Grounds for concern: SDLT mixed-use filings
Ben Clarke
Lydia Hutchinson
Lydia Hutchinson and Ben Clarke (Birketts) review recent SDLT mixed-use cases and the limits of relying on grazing, agricultural use or future plans.
Responding to Sch 36 notices: a practical guide
Richard Jeens
Stephanie Mullins
Stephanie Mullins and Richard Jeens (Slaughter and May) explain how to
take control of Sch 36 notices by engaging early with HMRC to narrow scope
and responding strategically.
Show and tell: the changing face of disclosure in tax litigation
Jack Prytherch
Yousuf Chughtai
The starting point Under Rule 27 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules, SI 2009/273 (as amended) (‘the FTT rules’), each party in standard or complex cases need only provide the other with a list of documents...
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
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
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others 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
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030