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Uncertain tax treatments
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Uncertain tax treatments
UNCERTAIN-TAX-TREATMENTS
The curious case of Uncertain Tax Treatments
Jack Prytherch
Yousuf Chughtai
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
Kate Alexander
Nick Evans
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
Zoe Andrews
Mike Lane
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
Craig Kirkham-Wilson
Gary Barnett
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HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Kate Alexander
Nick Evans
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
Zoe Andrews
Mike Lane
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HMRC's draft guidance on notification of uncertain tax treatments
HMRC has issued its draft guidance on the proposed reporting regime.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
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Finance Bill 2026: Government tables extensive Report Stage amendments
Spring Forecast leaves tax policy unchanged
Increase in ATED chargeable amounts
LBTT exemption for CoACS transactions
Business growth restricted to avoid £90k VAT threshold
CASES
Read all
UK Care No. 1 Ltd v HMRC
Aspire in the Community Services Ltd v HMRC
A Outram and another v HMRC
Other cases that caught our eye: 6 March 2026
Lycamobile UK Ltd v HMRC
IN BRIEF
Read all
To have and to hold (over)
HMRC’s guidance on the 40% first year allowance
No partnership, no relief
Crypto things
Tax efficient trust planning with surplus income
MOST READ
Read all
To tax or not? Gourley revisited
Consultation tracker
HMRC manual changes: 27 February 2026
Lycamobile UK Ltd v HMRC
Other cases that caught our eye: 27 February 2026