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TRADING
Demystifying the Substantial Shareholdings Exemption
Jennifer Plummer
Jennifer Plummer (BDO) considers the requirements for this valuable relief
and outlines some of the complexities involved where corporate structures are
not straightforward.
Other cases that caught our eye: 5 September 2025
FoI request: In Thomas Elsbury v The Information Commissioner [2025] UKFTT 915 (GRC) (2 August), the FTT (General Regulatory Chamber) allowed an appeal against an Information Commissioner Decision Notice upholding HMRC’s decision to neither...
ScottishPower and the limits of von Glehn
Suzanne Hill
Rupert Shiers
Rupert Shiers and Suzanne Hill (Hogan Lovells) examine a recent ruling on whether a corporation tax deduction is allowable for significant expenditure in settling a regulatory investigation.
Private client review for October 2024
Edward Reed
Clare Wilson
Edward Reed and Clare Wilson (Macfarlanes) review the latest cases on EIS,
BPR, reasonable excuse, and the principles of open justice and privacy.
Putney Power Ltd and another v HMRC
Company did not commence trading before EIS deadline.
A capital blow for deducting management expenses
Kyle O'Sullivan
The Supreme Court has delivered its judgment in
Centrica Overseas Holdings
.
Kyle O’Sullivan (BCLP) reviews the case and its implications.
Ask an expert: Will a virtual server give rise to a taxable presence in the UK?
Christopher Eames
A server physically located in the UK cannot give a person a permanent establishment in the UK. Christopher Eames (Mishcon de Reya) considers a real life scenario which tests the limits of that principle.
Tax aside? Private investment fund side letters
Deepesh Upadhyay
Benjamin Shem-Tov
Ben Jones
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds
Sutherland) examine the increasing use of side fund letters in a private
investment funds context and the associated most favoured nations process.
Tax clouds on the Horizon for the Post Office?
Heather Self
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
Lockdown: tax on prolonged business interruption
Catherine Hill
Catherine Hill (Macfarlanes) sets out a series of recommendations for
businesses to mitigate adverse tax consequences following lockdown.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
New HMRC manual on Mandatory Registration of Tax Advisers
New Advance Tax Certainty Manual
HMRC relax ERS reporting for short-term business visitors
HMRC update SP 1/2001
VAT Notice 742A clarification
CASES
Read all
Bagshaw Ltd v Revenue Scotland
HMRC v Healthspan Ltd
Other cases that caught our eye: 5 June 2026
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
IN BRIEF
Read all
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
MOST READ
Read all
TP adjustments and VAT: lessons from Stellantis Portugal
HMRC clarify CIS financing positions
Consultation tracker
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime