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COMPLIANCE
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
Matthew Rowbotham (Lewis Silkin) examines the Government’s consultation on double taxation for UK individuals in US LLCs and finds much to welcome, as well as some important issues still to resolve.
The CBAM trilemma
Joshua Stevens
The UK’s Carbon Border Adjustment Mechanism launches in January 2027.
Joshua Stevens (Pump Court Tax Chambers) explains what’s proposed – and
why it risks exacerbating trade tensions at a time of rising protectionism.
R&D Disclosure Service: the best route to resolution?
Jon Claypole
Jack Sloggett
Jon Claypole and Jack Sloggett (BDO) welcome HMRC’s new R&D
Disclosure Service but explain it is not suitable in all circumstances.
Off-payroll workers: the new rules for umbrella companies
Steven Porter
Penny Simmons
The rules are another example of HMRC requiring businesses to police tax
compliance across their supply chains, write Penny Simmons and
Steven Porter (Pinsent Masons).
Tax Administration Framework Review: dull sounding, but far reaching
Daniel Lusted
Daniel Lusted (BDO) examines what’s being proposed.
Transfer pricing compliance: a guiding hand and a warning
Simon Wood
HMRC are clearly not happy with the standard of analysis and documentation
that they are currently seeing, writes Simon Wood (BDO).
Pillar Two: assessing the impact on the UK FTSE 100
Alistair Nichol
Lavina Hassasing
The expected impact of the new Pillar Two regime is starting to unfold as
the first UK groups have filed their calendar year-end consolidated accounts,
write Alistair Nichol and Lavina Hassasing (Evelyn Partners).
The UK’s international disclosure rules: where are we now?
Sharon Baynham
Sharon Baynham (KPMG) explains how the new reporting rules differ from DAC 6 and what action tax professionals should be taking.
The new failure to prevent fraud offence: cheating the public revenue
Dominic Stuttaford
Dominic Stuttaford (Norton Rose Fulbright) considers the scope of a new ‘failure to prevent’ offence and how it differs from the existing corporate criminal offences.
CCO investigations: had the horse already bolted?
Jason Collins
Laura Ford
Jason Collins and Laura Ford (DLA Piper) take stock of the corporate criminal offence in view of recent statistics showing no charges to date and just nine live investigations.
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EDITOR'S PICK
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
1 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
2 /7
The new Securities Transfer Tax: business as usual?
Georgina West
3 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
4 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
5 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
6 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
7 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Perenco UK Ltd v HMRC
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?