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COMPLIANCE
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
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).
The ICTS: a new chapter in transfer pricing compliance
Amy Clarke
Andrew Stewart
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
Zoe Andrews
Mike Lane
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
Jack Prytherch
Yousuf Chughtai
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’.
Improving HMRC’s approach to dispute resolution
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
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87
EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
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
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
New HMRC withholding tax guidance
Tax Journal's 2026 Budget coverage
Budget 2026: Sovereign immunity - a more considered reform
Budget 2026: the tax measures