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Tax treatment
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Tax treatment
TAX-TREATMENT
To tax or not? Gourley revisited
Eloise Walker
When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.
A new service for tax certainty on major projects
Finn Halton
Gregory Price
HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).
Risky business: the basics and use cases of tax insurance
Kate Pearson
Annabelle Trotter
Helen Coward
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)
Frankie Beetham
Ceinwen Rees
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
Shayaan Zaraq Bari
Nicholas Gardner
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.
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of
5
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
Tax Journal authors for October
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
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