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Tax treatment
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TAX-TREATMENT
Risky business: the basics and use cases of tax insurance
Kate Pearson
Helen Coward
Annabelle Trotter
The tax insurance market has grown significantly. Helen Coward (Simmons &
Simmons) speaks with Annabelle Trotter and Kate Pearson (Howden) about
how it is now used across an increasingly broad range of transactions.
Forex: recent UK tax developments
Tamar Ruiz
Matthew Mortimer
Matthew Mortimer and Tamar Ruiz (Mayer Brown) examine key recent
changes to the UK taxation of foreign exchange gains and losses.
Carry on paying on account (or risk paying more)
Ceinwen Rees
Frankie Beetham
The newly reformed tax on carried interest will subject carried interest to the
payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland
& Ellis) set out some of the key practical considerations.
Beard: dividends of a capital nature
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) explains why form matters.
Certainty in uncertain times
Erica Rees
Jenny Doak
Jenny Doak and Erica Rees (Weil, Gotshal & Manges) consider some of the
practical considerations surrounding the proposed process for providing
advance tax certainty for major projects.
Whistleblowing
David Whiscombe
The Government’s plan to launch a new tax whistleblower scheme raises a
number of questions – and it’s not clear how many have been fully thought
through, writes David Whiscombe.
A Moffat and another v HMRC
Holding company was not ‘trading’ for entrepreneurs’ relief purposes
Insuring M&A tax risks: practical considerations for buyers
Nicholas Gardner
Shayaan Zaraq Bari
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining
W&I insurance with other tools may help bridge any gaps in tax risk coverage
and maximise protection for buyers.
HMRC v P Gould
Upper Tribunal upholds FTT decision on when interim dividend was ‘paid’.
What is the UK tax treatment of Dubai (DIFC) Foundations?
Kyra Motley
Will Timbrell
There is no equivalent to a Foundation registered with the Dubai International
Finance Centre Registrar of Companies under English law. How then should
they be treated for UK tax purposes? Kyra Motley and Will Timbrell
(Boodle Hatfield) investigate.
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4
EDITOR'S PICK
Tax Journal's 2025 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 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: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Finance Bill 2026 published
Tax in 2025: the good, the bad and the ugly
A year at the Tax Bar in 2025
End of year musings on corporate tax
R&D tax in 2025: the calm after the storm?