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COMPLIANCE
Tax and the City review for May 2019
Zoe Andrews
Mike Lane
Hybrid capital instruments technical noteFA 2019 repealed and replaced the regulatory capital securities regime from 1 January 2019 with a new hybrid capital instrument (HCI) regime. An HCI is a loan relationship under which the debtor (but not the...
NCL Investments Ltd: accounting not optional
Thomas Dalby
Thomas Dalby (Gabelle) reviews an Upper Tribunal decision on CT deductions for share options.
Derry: carry back of share loss relief
Michael Avient
What is and is not included in a self-assessment? Michael Avient examines the taxpayer victory at the Supreme Court on a carry back loss claim.
FA 2019: diverted profits tax
Ross Robertson
FA 2019 makes several changes and additions to the diverted profits tax (DPT) legislation within FA 2015 Part 3.The DPT impacts multinational businesses where transactions between the UK and foreign companies are perceived to lack economic substance...
FA 2019: leases
David Porter
Schedule 14 of this years Finance Act impacts lessees accounting under IFRS 16 for periods of account starting on or after 1 January 2019. IFRS 16 brings operating leased assets onto the balance sheet of the lessee for the first time, and the...
The EC’s group finance exemption state aid ruling
Dan Neidle
Rob Sharpe
The European Commission concludes that part of UK’s CFC tax regime gave unlawful state aid to certain multinational companies. Dan Neidle and Rob Sharpe (Clifford Chance) report.
Tax implications of LIBOR discontinuation
Bridget English
Richard Sultman
Bridget English and Richard Sultman (Cleary Gottlieb) discuss key tax issues arising from the anticipated discontinuation of LIBOR and transition to alternative ‘nearly risk free’ rates.
April 2019 tax changes
Dan Nazarian
Mark Groom
Patricia Mock
Donna Huggard
This report, which sets out the key tax changes taking effect from April, was prepared by Deloitte’s Mark Groom (partner), Patricia Mock (tax director), Dan Nazarian (associate director) and Donna Huggard (associate director).
Intangible fixed assets: FA 2019 changes to goodwill and degrouping charges
Sarah Gabbai
Sarah Gabbai (McDermott Will & Emery) considers two important changes to the IFA regime introduced by the Finance Act 2019.
Self's assessment: what a relief!
Heather Self
In our continuing series, Heather Self examines some of the tax issues that make the headlines of the national press. This week, she looks at the cost of tax reliefs.
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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 to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
Umbrella companies: new HMRC PAYE guidance
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
Read all
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
UK-Vietnam tax treaty updated