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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be withdrawn.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HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments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HMRC's draft guidance on notification of uncertain tax treatments
HMRC has issued its draft guidance on the proposed reporting regime.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
Spare us the cUTTer
Nick Thornton
1 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
2 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
3 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
4 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
5 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
6 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
7 /7
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
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
NEWS
Read all
Foreign Permanent Establishment exemption to be made mandatory
Chancellor announces package of road fuel measures
Quarterly advisory fuel rates published
New Isle of Man social security agreement signed
Streeting proposes CGT equalisation in ‘wealth tax’ plan
CASES
Read all
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
H Gwyn-Jones v HMRC
Other cases that caught our eye: 29 May 2026
HC-One No 1 Ltd v HMRC
IN BRIEF
Read all
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
The growing problem of the personal allowance phase down
Situs: loan notes
MOST READ
Read all
HC-One No 1 Ltd v HMRC
Take 3.9 TV Partnership and others v HMRC
When Homer nods: the rise of the Inco principle in tax
The growing problem of the personal allowance phase down
Trustees IHT exposure from 6 April 2025