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CGT
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CGT
CGT
At your disposal: conditionality under TCGA 1992 s 28
Rebekka Sandwell
Colin Askew
Rebekka Sandwell and Colin Askew (Eversheds Sutherland) consider the use of ‘conditional contracts’ in order to benefit from pre-Budget CGT rates.
Time is tight: CGT and the Autumn Budget
Peter Rayney
Peter Rayney (Peter Rayney Tax Consulting) discusses some strategies for
CGT tax planning in readiness for the upcoming budget.
Partnerships and SP D12
Tanja Velling
Alex Sim
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Misunderstanding purpose in Osmond and Allen
Thomas Chacko
The First-tier Tribunal’s ruling in Osmond and Allen reveals a mistaken approach to the transactions in securities rules, and to purpose tests in general, writes Thomas Chacko (Pump Court Tax Chambers).
Back to basics: Sale of assets at under value
Sadiq Hashmi
Ben Handley
A back to basics guide, by Ben Handley and Sadiq Hashmi (BDO).
Tax and the City review for October 2023
Zoe Andrews
Mike Lane
Tricky timings, difficult delineations, punitive payments... Mike Lane and
Zoe Andrews (Slaughter and May) review the latest developments that matter.
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
Back to basics: Section 260 holdover relief
Paul Townson
Sophie Mehta
Paul Townson and Sophie Mehta (BDO) provide a back to basics guide to this valuable relief which can help the transferor with their immediate CGT implications of gifting assets.
Back to basics: Section 165 holdover relief
Paul Townson
Chris Holmes
Chris Holmes and Paul Townson (BDO) provide a back to basics guide on this valuable relief.
Slade: land owning dispute costs not allowed
Julie Butler
Fred Butler
Julie Butler and Fred Butler (Butler & Co Alresford) examine an FTT case that denied a deduction for legal expenditure incurred defending rights to a number of assets ‘collectively’ when one of those assets was sold separately.
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC