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Contentious tax quarterly: Spring 2026
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) review recent decisions on costs for unreasonable behaviour, the use of AI in litigation and the scope of the FTT’s jurisdiction, as well as increased HMRC criminal investigations into advisers.
Penalty suspension
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
BTR late than never: SDLT overpayment relief
Helen Coward
‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.
Headless chickens: Morrisons and the FTT’s supervisory jurisdiction
Yousuf Chughtai
Jack Prytherch
The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).
The VAT review for March 2026
Gary Barnett
Gary Barnett (Simmons & Simmons) reviews recent VAT developments, including the Upper Tribunal’s decision in Lycamobile and CJEU guidance on statutory payments.
Back to square one: late appeals after Medpro
Liam McKay
Adam Craggs
The Court of Appeal restores a strict approach to late appeals, leaving taxpayers facing the familiar
Martland
hurdle once again, write Adam Craggs and Liam McKay (RPC).
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Emily Osborne
The Upper Tribunal confirms that bank transfers are remittances and reopens the question of offshore credit cards, writes Emily Osborne (Fladgate).
TOMS, taxis and private hire vehicles
Damon Wright
Damon Wright (K3 Tax Advisory) examines the Finance Bill provisions.
Trouble in store for the Sehgals
John Shallcross
John Shallcross (Blake Morgan) examines the counter-intuitive result in a mixed property SDLT decision.
Acting ‘as such’: the special legal regime after Northumbria Healthcare
Denis Edwards
A recent Supreme Court judgment is now the starting point for identifying when a special legal regime exists, writes Denis Edwards (Temple Tax Chambers).
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of
20
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
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
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
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The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer