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TRADING
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
Rupert Shiers
Suzanne Hill
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
Clare Wilson
Edward Reed
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.
Cobalt: golden contracts, EZAs and legitimate expectation
Sam Wardleworth
Catherine Robins
Catherine Robins and Sam Wardleworth (Pinsent Masons) review an interesting Upper Tribunal decision on the test for trading, 'golden contracts' and the availability of enterprise zone allowances and legitimate expectation.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 26 September 2025
HMRC to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
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P Collingwood v HMRC
The hidden costs of a cap on lifetime gifting
The future of international tax reform
UK-Vietnam tax treaty updated
The Prudential Assurance Company Ltd v HMRC