Market leading insight for tax experts
Subscribe
Home
Saved articles
Viewed articles
Login
Logout
E-newsletter
Advertise
About us
Help
View online issue
BROWSE BY TOPIC
Corporate Taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect Taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International Taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private Business Taxes
OMBs
Partnerships
Private Client Taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real Estate Taxes
Property taxes
REITs
Stamp Taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
NEWS
CASES
IN BRIEF
ANALYSIS
ONE MINUTE WITH
PEOPLE & FIRMS
TRACKERS
AUTHORS
ISSUE ARCHIVE
BROWSE BY TOPIC
Corporate taxes
Compliance
Corporation tax
DPT
Groups
Transactional tax
Employment taxes
Employment taxes
Termination payments
Indirect taxes
Customs & Excise duties
Environmental taxes
IPT
VAT
International taxes
BEPS
CFCs
Cross border
Double tax relief
Foreign profits
Residence
Transfer pricing
UK competitiveness
Withholding taxes
Private business taxes
OMBs
Partnerships
Private client taxes
CGT
IHT
Pensions & investments
Trusts & estates
Real estate taxes
Property taxes
REITs
Stamp taxes
SDLT
SDRT
Tax policy & administration
Anti-avoidance
Appeals
Brexit
Compliance
HMRC Powers
Investigations
Litigation
Tax policy
Tax risk
Subscribe
Home
Saved articles
Viewed articles
View virtual issue
View online issue
Login
Logout
E-newsletter
Advertise
About us
Help
News
Cases
In brief
Analysis
One Minute With
People & Firms
Trackers
Authors
Issue Archive
SEARCH
Home
Upper Tribunal
Home
Upper Tribunal
UPPER-TRIBUNAL
Tax and the City for September 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions
on treaty interpretation, deeming provisions and group litigation orders,
alongside HMRC’s latest performance figures.
Ready, set, trade: when does a trade begin and when does it matter?
Elissavet Grout
Hannah Manning
When does preparation become trading? Hannah Manning and Elissavet Grout (Travers Smith) explore why the Upper Tribunal’s Putney Power decision matters for EIS, EMI, SSE and other tax reliefs.
TOMS: a narrower road after Bolt Services
Dr Michael Taylor
Dr Michael Taylor (PwC) explains how the Court of Appeal’s Bolt Services decision narrows the scope of the Tour Operators’ Margin Scheme.
Show and tell: the changing face of disclosure in tax litigation
Jack Prytherch
Yousuf Chughtai
The starting point Under Rule 27 of the Tribunal Procedure (First-tier Tribunal) (Tax Chamber) Rules, SI 2009/273 (as amended) (‘the FTT rules’), each party in standard or complex cases need only provide the other with a list of documents...
Queenscourt: a dip in legal certainty
Fabian Barth
James Hurst
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
Tax and the City for May 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) provide their unique perspective on the impact of recent rulings from the higher courts and the OECD’s latest findings on the UK’s rising tax burden on labour.
Lycamobile UK: guaranteed availability, guaranteed VAT
Julius Konstantin Berling
Liesl Fichardt
Liesl Fichardt and Julius Berling (Quinn Emanuel) assess the Upper Tribunal ruling in Lycamobile and its implications beyond telecoms.
How close is close enough? Orsted and the limits of ‘on the provision of plant’
Paul Farey
Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.
Penalty suspension
Jake Landman
Abigail McGregor
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Henry Bennett-Gough
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in
Boston Consulting Group
and its implications for mixed member LLP structures.
Go to page
of
9
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Tax Journal authors for October
Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030