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TAX-RELIEF
International review for March 2026
Tim Sarson
Once again, the US dominates the international tax news cycle, reports
Tim Sarson (KPMG).
R&D tax in 2025: the calm after the storm?
Jenny Tragner
Jennifer Tragner (S&W) considers an unsettled year for R&D reliefs, where
transitional rules, evolving guidance and emerging AI questions kept advisers
busy despite few new policy changes.
Budget 2025: Complaints old and new: what the Budget really tells us about tax
David Milne KC
There will be the usual complaints about the tax burden on working people, but it is very modest compared with the 1960s and 1970s, when the top rate of income tax was still 98%, imposed to pay the USA for the monies lent to us for WW2. There will...
Five (S)EIS pitfalls for the unwary
Philip Hare
Administrative errors can jeopardise SEIS and EIS relief, even when advance
assurance has been received from HMRC, as Philip Hare (Philip Hare &
Associates) explains.
Legislation day 2025: R&D relief for Northern Ireland businesses
Jenny Tragner
The rushed implementation of ERIS continues to demonstrate why legislation should be properly consulted on before implementation.
Enhancing UK tax policy: a blueprint for supporting technological innovation
Kate Murphy
Dominic Mathon
A more ambitious approach to tax policy, informed by international best
practices, could enhance the UK’s ability to convert its research prowess into
commercial success, write Dominic Mathon and Kate Murphy (RELX).
The Big, Beautiful Bill: one House down, one House to go
Andrew Solomon
As the Senate prepares to take up President Trump’s sweeping tax and spending
package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions
and what happens next.
Other cases that caught our eye: 20 June 2025
Application on the ‘wholly and exclusively’ test of deductibility: The wholly and exclusively rule governing the deductibility of expenses has been part of the tax code since 1842, so it is more than a little surprising to find a taxpayer...
HMRC’s defeats on subsidised and contracted out R&D
Benjamin Craig
Benjamin Craig (Ayming) examines the impact of two recent FTT decisions.
Film tax reliefs: HMRC roll out the red carpet
Nicola Simmons
Nicola Simmons (Mishcon de Reya) examines the new tax reliefs introduced
to promote more film production in the UK.
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4
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
HMRC step up VAT scrutiny as large and medium sized-business investigations rise 31%
Government announces increase to Electricity Generator Levy
CIR returns
HMRC issue updated VAT road fuel scale charges
CCA scheme extended to new sectors and updated guidance issued
CASES
Read all
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
Centrica Energy Storage Ltd v HMRC
Clearwater Hampers Ltd v HMRC
Other cases that caught our eye: 24 April 2026
CATS North Sea Ltd v HMRC
IN BRIEF
Read all
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
ATED: a reminder
UK short-term business visitors: the Appendix 4 report
Tax advisers: sanctionable conduct
MOST READ
Read all
Tax advisers: sanctionable conduct
Section 171A elections
HMRC loans to participators tool
Mega Marshmallows and the meaning of ‘normally’
Clearwater Hampers Ltd v HMRC