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Tax and the City review for July 2025
Mike Lane
Zoe Andrews
Osmond, Eastern Power Networks
and HMRC’s guidance on their new
unilateral APA process are among the developments in this month’s review
by Mike Lane and Zoe Andrews (Slaughter and May).
Contentious tax quarterly: Summer 2025
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) review some notable rulings on a
range of procedural issues, as well as recent changes to the tribunal rules.
The VAT review for July 2025
Gary Barnett
Jo Crookshank
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers recent decisions on the single/multiple supply rule and the
VAT finance intermediation exemption, as well as HMRC’s change of policy on
pension scheme costs.
Competing views on the VAT exemption for medical care
Alex Spencer
Two recent cases demonstrate that the scope of the VAT exemption for health
and welfare is far from certain, writes Alex Spencer (Field Court Tax Chambers).
Improving HMRC’s approach to dispute resolution
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
Findings of fact are stubborn things: A Taxpayer v HMRC
Dominic Lawrance
Catrin Harrison
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys)
consider the implications of the Court of Appeal judgment.
Bagshaw Ltd v Revenue Scotland
Glasgow townhouse and mews properties were non-residential for LBTT purposes
Take 3.9 TV Partnership and others v HMRC
Film production companies payments were allowable deductions
J Herrmann v HMRC
No late payment penalties on reallocation of earlier tax payments
J Krason v HMRC
Penalties: reliance on trusted accountant
Go to page
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17
EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime