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Uncertain tax treatments
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Uncertain tax treatments
UNCERTAIN-TAX-TREATMENTS
Spare us the cUTTer
Nick Thornton
Nick Thornton (Fried Frank) argues that HMRC’s proposed expansion of
the UTT regime is the wrong answer to the wrong question, and should
be withdrawn.
The curious case of Uncertain Tax Treatments
Yousuf Chughtai
Jack Prytherch
HMRC’s newly published materials raise important questions about
how taxpayers are engaging with the UTT regime in practice, writes
Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
10 questions on Uncertain Tax Treatment
Abigail McGregor
Steven Porter
Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT
regime after two years of operation.
Uncertain tax treatment: highlights from HMRC’s final guidance
Nick Evans
Kate Alexander
Kate Alexander and Nick Evans (Baker McKenzie) review the newly published
Uncertain Tax Treatments by Large Businesses Manual.
Tax and the City review for November 2021
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) consider Autumn Budget/Finance Bill measures relevant to financial institutions and the latest on international tax reform.
The VAT review for October 2021
Gary Barnett
Craig Kirkham-Wilson
Gary Barnett and Craig Kirkham-Wilson (Simmons & Simmons) provide your monthly guide to the latest VAT developments that matter.
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Nick Evans
Kate Alexander
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
Tax and the City review for September 2021
Mike Lane
Zoe Andrews
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
HMRC's draft guidance on notification of uncertain tax treatments
HMRC has issued its draft guidance on the proposed reporting regime.
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
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Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
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The VAT treatment of prize draws
Loan charge settlement scheme: regulations and guidance published
The new duty to correct tax return errors
Requirements for forthcoming pensions IHT changes
Consultation tracker