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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
Gary Barnett
Jo Crookshank
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
Lydia Hutchinson
Ben Clarke
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
Stephanie Mullins
Richard Jeens
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
Yousuf Chughtai
Jack Prytherch
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...
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
Craig Kirkham-Wilson
Lauren Trask
Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.
Tax and the City for July 2026
Mike Lane
Zoe Andrews
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.
Queenscourt: a dip in legal certainty
James Hurst
Fabian Barth
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
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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