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Other cases that caught our eye: 6 February 2026
HICBC and taxpayer’s use of AI: In R Huish v HMRC [2026] UKFTT 129 (TC) (16 January), the FTT allowed the taxpayer’s appeal against discovery assessments purportedly charging him to the high income child benefit charge (HICBC) for 2015/16. HMRC made...
J Boulting v HMRC
Purchase of own shares benefited company’s trade
W Tinkler v HMRC
Scope of closure notices
Other cases that caught our eye: 23 May 2025
Trade losses not recoverable: Losses made in a trade carried on by a sole trader can be set against his or her other income. However, relief is not available where the trade is not carried on a commercial basis with a view to profit. C Macdonald v...
The CBAM trilemma
Joshua Stevens
The UK’s Carbon Border Adjustment Mechanism launches in January 2027.
Joshua Stevens (Pump Court Tax Chambers) explains what’s proposed – and
why it risks exacerbating trade tensions at a time of rising protectionism.
The Trump effect: US foreign tax policy
Tanja Velling
Among the executive orders signed by President Trump is a firm rebuff of the OECD’s two-pillar solution, writes Tanja Velling (Slaughter and May).
CATS North Sea Ltd v HMRC
Transfer of trade and capital allowances provisions in context of ring fence trade.
A D Bly Groundworks and Civil Engineering Ltd and another v HMRC
Provision for future payments under an unfunded retirement benefit scheme not wholly and exclusively for trade purposes.
Investment and Securities Trust Ltd v HMRC
Option not acquired for exclusive purpose of a property development trade
Ingenious, but flawed
David Whiscombe
The importance of the basics.
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2
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
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
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
Tax Update 2026: government publishes simplification and compliance package
HMRC asked to clarify CIS treatment of development finance
HMRC Transfer Pricing and Profit Diversion Compliance Facility
ICTS consultation
UK-India Double Contributions Convention arrangements extended
CASES
Read all
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
Other cases that caught our eye: 26 June 2026
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Solving the LLC double taxation problem
Consultation tracker
Foreign PE exemption becoming mandatory
HMRC v GCH Corporation Ltd and others
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’