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COMPLIANCE
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
GfC 13 and the filing position: nothing to see here?
Angela Savin
Andrew James
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
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).
The ICTS: a new chapter in transfer pricing compliance
Andrew Stewart
Amy Clarke
The International Controlled Transaction Schedule is expected to be
introduced in the UK in the foreseeable future. Andrew Stewart and
Amy Clarke (BDO) explain how to prepare.
Tax and the City review for September 2025
Mike Lane
Zoe Andrews
The tribunal decision in
Currys
on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
A storm for umbrellas: joint liability on the horizon
David Harmer
With joint and several tax liability being introduced for those contracting with umbrellas, David Harmer (Markel Tax) explains how to keep your clients protected.
Mining for information: preparing for CARF
Yousuf Chughtai
Jack Prytherch
CARF may be just the beginning of a new age of tax enforcement and
scrutiny for the crypto industry, write Yousuf Chughtai and Jack Prytherch
(Osborne Clarke).
Legislation day 2025: Tackling non-compliance in the umbrella company market
Rebecca Seeley Harris
Introducing the ‘purported umbrella’.
VAT assessment time limits: an affront to legal certainty
Fabian Barth
Fabian Barth (Alvarez & Marsal) examines the distinction between when an
assessment is ‘made’ and ‘notified’.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 17 October 2025
Reeves should ‘grasp the nettle’ on tax reform, says IFS
HMRC raise game on football clubs
Conservatives would scrap SDLT, says Badenoch
Tax treatment of cryptoasset exchange traded notes
CASES
Read all
Mainpay Ltd v HMRC
Dialog Semiconductor Ltd v HMRC
Hippodrome Casino Ltd v HMRC
Other cases that caught our eye: 17 October 2025
GW Martin & Co Ltd and another v HMRC
IN BRIEF
Read all
Taking cover
More on s 455
HMRC’s technical note on RIFs
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
MOST READ
Read all
Isle of Wight NHS Trust v HMRC
GW Martin & Co Ltd and another v HMRC
HMRC manual changes: 10 October 2025
No escape: the new IHT tax rules for pensions
Other cases that caught our eye: 10 October 2025