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CORPORATION TAX
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
Lisa Shipley
Alison Lobb and Lisa Shipley (Deloitte) examine what the new mandatory
foreign branch exemption means for UK businesses.
Legislation Day: draft Finance Bill 2027
A detailed report by Lexis+® UK Tax, with additional practitioner insight.
The VAT review for July 2026
Gary Barnett
Karen Bannister
In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.
Company tax return standardisation: clarity or challenge?
Andrew Hawley
Andrew Hawley (Crowe UK) weighs the trade-off in HMRC’s CT return
reforms: fewer routine ‘what does this mean?’ enquiries on the one hand,
more targeted scrutiny of complex and subjective positions on the other.
Muller: notional companies and real-world transactions
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) considers the Court of Appeal’s decision in Muller, which raises important questions about the application of the CTA 2009 s 1259 deeming rule to partnership and LLP restructurings involving corporate members.
To tax or not? Gourley revisited
Eloise Walker
When should damages be calculated net of tax? Eloise Walker (Pinsent Masons) revisits the Gourley principle and its practical implications for commercial disputes.
TP and UTPP in Finance Bill 2026: more complexity and uncertainty
David Haughey
Sarah Bond
Edward Buxton
The Finance Bill rules introduce further complexity to the earlier draft
provisions and place an unwelcome reliance on HMRC guidance, write
Sarah Bond, Edward Buxton and David Haughey (Freshfields).
Demystifying the Substantial Shareholdings Exemption
Jennifer Plummer
Jennifer Plummer (BDO) considers the requirements for this valuable relief
and outlines some of the complexities involved where corporate structures are
not straightforward.
Budget 2025: Two things about corporation tax
Eloise Walker
When I originally suggested writing this comment piece, I thought I was going to be writing about exciting changes in partnership taxation, and various other interesting developments in the world of corporate tax. That all went out the window before...
Lifecycle of a transaction: tax disputes on intra-group debt
Ravi Ahlawat
Lauren Redhead
Lauren Redhead and Ravi Ahlawat (DLA Piper) consider what to do when
HMRC enquire into deal funding, and provide a practical playbook from first
request to resolution.
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EDITOR'S PICK
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
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
NEWS
Read all
OECD issues Pillar Two review framework and revised GIR
VAT refund policy change for non-UK members of VAT groups
VAT on fund management services: new HMRC guidelines
Temporary zero rate for domestic electricity
CBAM admin regulations published
CASES
Read all
J Scheckter v HMRC
Luxurico Ltd v HMRC
C Sagar v HMRC
Other cases that caught our eye: 18 September 2026
The Executors of Hunt and others v HMRC
IN BRIEF
Read all
TOGCs and leases
Principal or agent?
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
MOST READ
Read all
Raising standards without regulating the profession
Grand Smile Design Ltd v HMRC
Consultation tracker
The Executors of Hunt and others v HMRC
J Scheckter v HMRC