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SETTLEMENTS
ScottishPower and the limits of von Glehn
Rupert Shiers
Suzanne Hill
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
L v HMRC
FTT holds discrimination settlement payment not taxable.
Clipperton revisited: open questions
Oliver Marre
Oliver Marre (5 Stone Buildings) considers the Court of Appeal decision and
its implications going forward.
School fee planning: back in the Spotlight
Gordon W Buist
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
Disguised remuneration: the new settlement opportunity
Tom Wallace
Thomas Wallace (WTT Consulting) explains what advisers need to do
to take advantage of the variety of tax treatments that are on offer.
Purpose and logic: Dunsby as a very modern tax case
Oliver Marre
Oliver Marre (5 Stone Buildings) examines a recent Upper Tribunal decision that demonstrates a modern approach to both the dividend taxing provisions and the settlement provisions found in ITTOIA 2005.
Murphy: earnings as profits and settlement payments
Darren Oswick
Matthew Norris
Darren Oswick and Matthew Norris (Simmons & Simmons) review a recent decision which suggests that insufficient attention has been paid to the ‘profit’ element of the earnings definition.
Seven lessons from Clipperton
Oliver Marre
A recent tribunal decision provides lessons on the settlement provisions,
Ramsay
and piercing the corporate veil, writes barrister Oliver Marre
(5 Stone Buildings).
Practical aspects of HMRC’s retrospective change on VAT and contract terminations
Clara Boyd
On 2 September 2020, HMRC published Revenue & Customs Brief 12/2020 setting out a change in the VAT treatment of payments made in respect of contract terminations and contractual disputes. HMRC’s new general rule is that most such payments will be...
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Transactions in Securities counteraction notices
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Finance Bill 2026 progress