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HMRC-POWERS
Too close for comfort? HMRC consult on a new reporting obligation for close companies
Rob Sharpe
Thomas Peet
Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals
to require close companies to report all transactions with participators,
assessing the likely compliance burden and unintended impact beyond small
businesses, particularly for private capital structures.
Private client review for May 2025
Sophie Dworetzsky
In this month’s review, Sophie Dworetzsky (Charles Russell Speechlys)
examines a case on distributions from an offshore company, a potentially farreaching
proposed change to the definition of permanent establishment and
the latest HMRC guidance.
Private client review for April 2025
Dominic Lawrance
Sophie Dworetzsky
They think it’s all over, it is now! Sophie Dworetzsky and Dominic Lawrance
(Charles Russell Speechlys) comment on the end of the remittance basis,
the ‘absolute mess’ that is the double remittance situation and a potentially
worrying change in HMRC’s view on the taxation of capital payments in
ancillary relief on divorce.
H Gwyn-Jones v HMRC
HMRC granted permission to amend their statement of case
Millennium Cash & Carry Ltd v HMRC
HMRC’s powers: Soft Drinks Levy
Impact Contracting Solutions Ltd v HMRC
HMRC’s power to deregister where VAT fraud
Navigating the protective assessment maze with Jeffries & Sons
Bryn Reynolds
Bryn Reynolds (Pinsent Masons) examines the recent
Jeffries
case which illustrates the potential taxpayer pitfalls surrounding protective assessments.
S Lefort v HMRC
Revocation of pension protection certificate.
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
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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
Read all
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