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Tax avoidance
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Tax avoidance
TAX-AVOIDANCE
Budget 2026: Tax compliance - little breathing space
Kate Ison
Budget 2026 was billed as providing ‘breathing space’ for businesses and families, but there was little let-up in the Government’s now well-trodden focus on tax compliance and enforcement. Although many of the compliance-related...
Home, a loan: the Court of Appeal’s ruling in Elborne
Louis Triggs
Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.
Legislation Day 2026: The securities transfer tax
Richard Sultman
Rob Sharpe
Key points to note.
How to apply for a non-statutory clearance from HMRC
A practical guide by Lexis®+ UK Tax examining when a non-statutory clearance is the right route, how to frame the application and how far HMRC’s response can be relied upon.
Loopholes and tax avoidance
Kyle Rainsford
What happens when tax planning appears to exploit a loophole? Kyle Rainsford (Addleshaw Goddard) reviews the courts’ anti-avoidance toolkit following the HC-One SDLT ruling.
Deductions after AD Bly: a shortcut for remuneration or pension provision?
Aparna Nathan
The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).
The 2025 loan charge review and Government response: the final chapter?
David Pett
All but one of the loan charge review’s ‘hard’ recommendations have been
accepted. David Pett (Temple Tax Chambers) assesses both the review and
the Government’s response – and considers the implications for affected
taxpayers and the new settlement opportunity.
Ask an expert: LLP to company - navigating incorporation relief
Claire Miles
QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...
Close encounters with close companies (part 2): common issues in practice
Ross McGregor
Hannah Manning
There is a myriad of anti-avoidance legislation which must be carefully
considered throughout the lifecycle of a close company. Hannah Manning
and Ross McGregor (Travers Smith) explain how to avoid some of the
common pitfalls.
Legislating against promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030