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Income tax
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Income tax
INCOME-TAX
R Grint v HMRC
Sale of occupation income tax charge
upheld.
Autumn Budget 2024: private capital
Tom Margesson
Elena Rowlands
Ian Zeider
Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) consider
the impact on the private capital sector, focusing on the changes announced to
the taxation of carried interest.
T Watts v HMRC
UT dismisses gilt strips scheme appeal.
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
HMRC’s assessment powers: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
The Scottish Budget 2024/25: widening the divergence
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) report on Scotland’s latest Budget, which introduces a new ‘advanced’ rate of income tax.
Tax in 2024 and beyond
Bill Dodwell
Increased digital reporting, the implementation of Pillar Two, potential further reforms to pensions tax... Bill Dodwell, former Tax Director of the Office of Tax Simplification, looks at what’s in store for tax in the year ahead.
BlueCrest Capital Management LP and others v HMRC
Court of Appeal confirms that treatment of final PIP awards are liable to income tax.
Top ten cases of 2023
Each week,
Tax Journal
reports notable judgments on tax issues that have been handed down by the courts and tribunals. This week, we also look back over 2023 and highlight some cases of interest to a wide range of advisers.
Resetting the clock and the six-year itch: non-domiciliaries resuming UK tax residence
Claire Weeks
Clare Maurice
Claire Weeks and Clare Maurice (Maurice Turnor Gardner) explain why
returning to the UK after a period of non-tax residence is not for the faint
hearted.
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of
9
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: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Finance Bill 2026 published
Tax in 2025: the good, the bad and the ugly
A year at the Tax Bar in 2025
End of year musings on corporate tax
R&D tax in 2025: the calm after the storm?