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Tax gap
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Tax gap
TAX-GAP
An increasingly tough stance on behavioural penalties
Sophie Rhind
Elvira Colomer Fatjo
Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
GfC 13 and the filing position: nothing to see here?
Angela Savin
Andrew James
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
Transformation Roadmap
Paul Aplin OBE
HMRC’s new roadmap heralds a step-change in the department’s digital
ambition, writes Paul Aplin OBE.
Legislation day 2025: MTD for Corporation Tax scrapped
Emma Rawson
… but reform is still on the cards.
Private client review for July 2025
Sophie Dworetzsky
This month’s update, by Sophie Dworetzsky (Charles Russell Speechlys).
Spring Statement 2025: minding the gap
Chris Sanger
Has the Chancellor found the secret to raising receipts without raising taxes?
Chris Sanger (EY) investigates.
Tax Administration Framework Review: dull sounding, but far reaching
Daniel Lusted
Daniel Lusted (BDO) examines what’s being proposed.
New anti-avoidance legislation: the liquidation of LLPs
Victoria Braid
Gideon Sanitt
The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
AI in tax administration: the need for taxpayer safeguards
Kunal Nathwani
There are questions over the use of AI by HMRC under the existing legislation
and the adequacy of current taxpayer safeguards, writes Kunal Nathwani
(Kirkland & Ellis).
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
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New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
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Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
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Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
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TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime