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Income tax
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Income tax
INCOME-TAX
No escape: the new IHT tax rules for pensions
Harriet Betteridge
Which pensions will be taxed? Who is responsible for reporting and paying
the tax? What’s the impact on planning? Harriet Betteridge (Charles Russell
Speechlys) examines some key questions surrounding the proposed legislation.
The Temporary Repatriation Facility opportunity
Alice Pearson
The Temporary Repatriation Facility could create significant tax savings
for some. Alice Pearson (Mercer & Hole) highlights some practical
considerations and areas of complexity.
OBBBA: a new era in Republican tax legislation
Aharon Friedman
Andrew Solomon
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the
One Big Beautiful Bill as a whole and look ahead to what’s next.
Carried interest: the L-day changes
Bezhan Salehy
Damien Crossley
The draft Finance Bill provisions seek to address some of the issues for credit
funds, write Bezhan Salehy and Damien Crossley (Macfarlanes).
The trials and tribulations of interest withholding tax
Bezhan Salehy
Elvira Colomer Fatjo
Rebecca Rose
Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes)
take a practical look at UK interest withholding tax, highlighting common
compliance pitfalls, HMRC’s approach and emerging complexities.
Other cases that caught our eye: 15 May 2026
Income tax and VAT assessments: In J Smith v HMRC [2026] UKFTT 663 (TC) (6 May), the FTT upheld HMRC’s income tax and VAT assessments and most penalties, while reducing the quantum and cancelling failure-to-file penalties where notices to file had...
CooperVision Lens Care Ltd v HMRC
Employment-related securities: differential exit proceeds taxable as earnings
HMRC v A O’Brien
FTT applies
Rangers
to contractor loan scheme and rejects s 29 defence
Carbon Six Engineering Ltd v HMRC
HMRC application to set aside barring order refused
Other cases that caught our eye: 6 February 2026
HICBC and taxpayer’s use of AI: In R Huish v HMRC [2026] UKFTT 129 (TC) (16 January), the FTT allowed the taxpayer’s appeal against discovery assessments purportedly charging him to the high income child benefit charge (HICBC) for 2015/16. HMRC made...
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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