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INCOME-TAX
Budget 2026: Real estate - a sovereign surprise
Elizabeth Bradley
The biggest news for the real estate sector was a change to the tax treatment of overseas sovereign investors from January 2029. That was a surprise. If an idea is dismissed, the real estate industry can be forgiven for thinking that it would not be...
Two models of unilateral taxation, and Poland’s hybrid
Sandy Bhogal
Graham Crocker
In October 2021, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) agreed a Two-Pillar Solution to address the tax challenges arising from the digitalisation of the economy. Pillar One of the Two-Pillar Solution contains two...
Legislation Day 2026: Aligning IT and NIC collection
David Whiscombe
A reform more than a decade overdue.
Deferred remuneration: HMRC update their guidance on cross-border tax and NICs
Nigel Doran
Lika Jatoeva
Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated
guidance on deferred remuneration for internationally mobile employees and
consider the resulting risks of double taxation and NICs mismatches.
MTD regulations: legislation at the eleventh hour
Emma Rawson OBE
Emma Rawson (ATT) reviews the MTD for Income Tax regulations,
highlighting late legislative changes, complex entry and exit rules, quarterly
reporting mechanics, and the wide-ranging exemption regime.
What is a Scottish taxpayer and what happens when they move during a tax year?
Chris Campbell
As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers.
PE: don’t believe the hype
Nick Thornton
Is the UK’s domestic Permanent Establishment definition reform fair,
simple and supportive of growth, or is it, in reality, yet further complexity,
asks Nick Thornton (Fried Frank).
A Budget for its times? The Scottish Budget 2026/27
Alan Barr
Isobel d'Inverno
Pre-election changes ease income tax for lower earners, while bigger tax reforms are pushed into the next parliament, report Isobel d’Inverno and Alan Barr (Brodies).
APR/BPR reform: a practitioner’s story
Stuart Maggs
This year has been a roller-coaster, writes Stuart Maggs (Howes Percival).
Budget 2025: Property taxes: it could have been worse
Elizabeth Bradley
Given the kite flying since August, you could expect the real estate industry to take a collective sigh of relief today. Many of the more radical ideas did not come to pass, such as removing the exemption from CGT on selling a main home of a higher...
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
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
NEWS
Read all
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others 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
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030