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Settlements
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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
Tax Journal's 2025 Autumn 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 Autumn 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: 28 November 2025
A Budget for complexity and delayed tax rises
UK’s largest companies generated over £90bn in taxes, according to 100 Group report
Land transaction tax reliefs extended to further tax sites
HMRC Wealthy Team’s nudge letters
CASES
Read all
AD Bly Groundworks and Civil Engineering Ltd v HMRC
Milton Park Holdings Ltd and another v HMRC
J Font v HMRC
Other cases that caught our eye: 28 November 2025
HMRC v Moir Management Services Ltd
IN BRIEF
Read all
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
Yet more Budget speculation
Fixing the FIG regime before extending it
The new non-dom rules
MOST READ
Read all
HMRC v Moir Management Services Ltd
J Dreyer v HMRC
OECD Model Tax Convention updated
Fixing the FIG regime before extending it
1st Alternative Medical Staffing Ltd v HMRC