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Tax and the City review for September 2025
Zoe Andrews
Mike Lane
The tribunal decision in
Currys
on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
Giving advice in uncertain times
Jeremy Mindell
Ongoing speculation over tax changes presents significant challenges for
delivering reliable advice, writes Jeremy Mindell (Primondell).
Leaving the UK? How to navigate the tax maze
Tim Lynch
Tahir Ebrahim
Tim Lynch and Tahir Ebrahim (BDO) provide a back to basics guide.
Private client review for March 2025
Dominic Lawrance
Sophie Dworetzsky
Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys) examine, among other things, some of the recent clarifications and outstanding concerns regarding both the non-dom reforms and the proposed changes to agriculture and business property reliefs.
Other cases that caught our eye: 17 July 2026
Employee benefit trust and IHT: In J McIlhone v HMRC [2026] UKFTT 995 (TC) (2 July), the FTT held that £4m appointed from an EBT to a sub-trust for one of the company’s two employees and his family ceased to qualify for the IHTA...
J Hosking v HMRC
Donations not part of ‘normal expenditure’
Other cases that caught our eye: 11 July 2025
Disguised remuneration schemes, end users and judicial review: It is now accepted that most, if not all, disguised remuneration schemes involving the making of loans to employees via an employee benefit trust do not work and that the arrangements...
Other cases that caught our eye: 4 July 2025
Interpreting double tax treaties: Vietjet Aviation Joint Stock Company v FW Aviation (Holdings) 1 Ltd [2025] EWCA Civ 783 (24 June) concerned a commercial dispute between two parties relating to the financing of the acquisition of four jet aircraft....
Other cases that caught our eye: 11 April 2025
IHT dispute concerning dividing estate residue: In S Changizi v P Changizi and another [2025] EWHC 735 (Ch) (2 April) is a dispute between mother and son as to how the burden of the IHT liability should be met. In this case, the English estate...
Private client tax in 2024: ch-ch-ch-changes*
Alyssa Haggarty
Claire Weeks
Changes to non-doms and IHT have dominated the year, but there have also been some interesting cases, write Claire Weeks and Alyssa Haggarty (Maurice Turnor Gardner).
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EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
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
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455