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Measuring Tax Gaps 2023: analysis and predictions
Craig Kirkham-Wilson
Craig Kirkham-Wilson (Simmons & Simmons) examines
Measuring Tax Gaps 2023
and predicts more enforcement activity in relation to large businesses.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Scottish Power (SCPL) Ltd and others v HMRC
Payments in lieu of penalties are non-deductible.
HMRC’s evolving approach to tax compliance for the largest businesses
Nicole Newbury
HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.
A tax on conscience? A moral dilemma for non-residents
Liam McKay
Robert Waterson
The Upper Tribunal has, for the first time, considered the meaning of ‘exceptional circumstances’ in the context of statutory residence – and it has set the bar extremely high, write Robert Waterson and Liam McKay (RPC).
Other cases that caught our eye: 8 September 2023
Calculating CJRS payments: We have seen a number of cases recently concerning the furlough (CJRS) scheme. Most of these have been about whether an employee meets the eligibility requirements. Ark Angel Ltd v HMRC [2023] UKFTT 705 (TC) (4 August 2023)...
JTIAC reaches the Upper Tribunal: onward, through the Slough of Despond, but for which purpose?
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) is disappointed by a recent Upper Tribunal decision on the unallowable purpose rule.
Judicial developments in recent treaty cases
David Goldberg QC
Constantine Christofi
Recent cases concerning the application of double tax treaties have seen the courts striving for common sense outcomes, write Constantine Christofi (RPC) and David Goldberg KC (Gray’s Inn Tax Chambers).
HMRC v Part 26A: can you cram the Crown?
Alex Lewis
Abby Martin
Lisa Rickelton
HMRC has recently had mixed fortunes when challenging ‘Part 26A cram downs’, as Lisa Rickelton, Alex Lewis and Abby Martin (FTI Consulting) report.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
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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
HMRC manual changes: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
The new share for share anti-avoidance
Concerns over the scope of new conduct rules for advisers
HMRC v Sintra Global Inc and another
Complex statutory construction: the Court of Appeal’s approach in Tower One
HMRC manual changes: 9 January 2026