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Home
Inheritance tax
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Inheritance tax
INHERITANCE-TAX
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hartley Foster (Addington Chambers) examines the right to obtain information from public authorities such as HMRC, via the Freedom of Information Act 2000, and the restrictions on that right.
Gifting APR/BPR assets on death
Simon Douglas
Simon Douglas (5 Stone Buildings) considers the will-drafting consequences of the new £2.5m allowance and its transferability – and explains why traditional ‘100% relief’ clauses may now not always achieve the desired result.
Private client review for January 2026
Sophie Dworetzsky
In this month’s update, Sophie Dworetzsky (Lombard Odier) reports the late change to the IHT reforms, the sharp increase in transparency and compliance obligations and some of the latest court rulings that matter.
Legislation day 2025: IHT on unused pensions
Penny Cogher
By ending the preferential treatment of discretionary pension schemes, the new rules aim to create parity across the public and private sectors, though at the cost of increased complexity for bereaved families and personal representatives.
Challenging the NICs Bill
Baroness Neville-Rolfe DBE CMG
The Shadow Treasury Minister in the House of Lords, Baroness Neville-
Rolfe DBE CMG, explains why and how the Opposition challenged the
Government’s NIC changes in the House of Lords.
Elborne: trusting that the loan will be deducted
Anthony Nixon
Anthony Nixon (Paris Smith) examines the first judicial ruling to accept that the double trust home loan scheme works to save inheritance tax.
APR and BPR reform: time to make hay while the sun shines?
Emma Haley
Hayden Bailey
After a wait of four months for more detail on the changes, what does
the consultation document now tell us? While there are some helpful
clarifications, not all of the concerns are addressed, write Hayden Bailey
and Emma Haley (Boodle Hatfield).
Lexgreen Services Ltd v HMRC
FTT considers the meaning of life
Ask an expert: Just how enforceable is UK inheritance tax abroad?
Alyssa Haggarty
Claire Weeks
Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the
status of the so-called ‘revenue rule’ and the options available to HMRC to
seek assistance in the collection of tax abroad.
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’