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PARTNERSHIPS
Muller: notional companies and real-world transactions
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.
Boulting: clarifying the purpose test in share buy-backs
David Whiscombe
Boulting
cannot be regarded as a satisfactory case, except as to its outcome in
favour of the taxpayer, writes David Whiscombe.
Ten cases shaping tax practice in 2026
As 2026 passes its halfway point, we take stock of a busy year in the courts. From decisions on partnership tax and treaty abuse to VAT, inheritance tax planning to employment status, here is our pick of ten key cases shaping tax practice this year....
Take 3.9 TV Partnership and others v HMRC
Film production companies payments were allowable deductions
R (oao Rokos) v HMRC
Promoters of film finance partnerships authorised to receive notice of enquiries into returns
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Upper Tribunal rules on payments under LLP ‘capital interests’ and the mixed member partnership rules
J O’Neil and others v HMRC
Redress payment taxable as post-cessation receipt
Milton Park Holdings Ltd and another v HMRC
No entitlement to deductions for amortisation of purchased goodwill
Brindleyplace Holdings S.à r.l (BP Holdings) v HMRC
No SDLT due on distributions of partnership and its properties following purchase of JPUT holding structure.
N Barklem v HMRC
High Court dismisses claim for declaratory relief in relation to failed film partnership scheme
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of
5
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Loan charge settlement scheme: regulations and guidance published
Requirements for forthcoming pensions IHT changes
One minute with... Tim Gummer