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Tax planning
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Tax planning
TAX-PLANNING
Complex statutory construction: the Court of Appeal’s approach in Tower One
Cristy Ajediti
Helen Coward
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
HMRC v GCH Corporation Ltd and others
UT confirms broad meaning of ‘business’
Other cases that caught our eye: 17 April 2026
Share loss relief: S Wilders v HMRC [2026] UKFTT 517 (TC) (1 April) is a claim for share loss relief arising from a failed attempt to recover treasure from the wreck of the ship the Merchant Royal, which sunk in 1641 off Land’s End. Investors...
Other cases that caught our eye: 25 October 2024
IHT implications under Forfeiture Act: Under the Forfeiture Act 1982, a person who has unlawfully killed another person cannot benefit from that person’s estate. However, where in the opinion of the court the justice of the case requires...
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
Other cases that caught our eye: 30 August 2024
Offshore employment: Bilfinger Salamis UK Ltd v HMRC [2024] UKFTT 736 (TC) (16 August) concerns the so-called host employer rules which apply where the ‘personal services’ of individuals employed by a foreign employer are ‘made...
When tax goes wrong
Michael Thomas KC
The position should be calmly evaluated at an early stage in order to put an
appropriate strategy in place, writes Michael Thomas KC (Pump Court
Tax Chambers). Easy to say in theory, but not always so easy to execute in
practice...
Are trusts an appropriate vehicle to hold shares in a family business?
Hayden Bailey
Hayden Bailey (Boodle Hatfield) considers the use of trusts as part of an ownership strategy for family businesses to enable succession planning.
G Haworth and others v HMRC
Upper Tribunal finds FTT correctly tested place of effective management of trusts.
Incorporation relief and ESC D32: a myriad of uncertainty
Gordon W Buist
Gordon W Buist (EQ Accountants) explains how the publication of
Spotlight 63 on landlord tax planning schemes has exposed a fundamental
flaw with incorporation relief from CGT.
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EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
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
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
Read all
UK closes the door on foreign branch loss relief
VAT capital goods scheme changes
New guidance on UK-India social security agreement
Mandatory registration brought into force, eventually
HMRC annual report: compliance yield tops £50bn
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
M Lambourne and another v HMRC
HMRC v Align Technology Switzerland GmbH and another
Other cases that caught our eye: 17 July 2026
HMRC v BlueCrest Capital Management (UK) LLP
IN BRIEF
Read all
Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
MOST READ
Read all
Consultation tracker
Tax and the City for July 2026
When Ramsay does not rescue HMRC
BlueCrest: the impact for asset managers
Legislation Day 2026: The securities transfer tax