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IPT
VAT
International taxes
BEPS
CFCs
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Home
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CORPORATION TAX
Pillar Two and the GloBE rules
Naomi Lawton
James Burton
Ellen Birkemeyer
Mitchell Fraser
James Burton, Ellen Birkemeyer, Naomi Lawton and Mitchell Fraser (Allen & Overy) provide a 20 questions guide.
The corporation tax increase is approaching: rate changes from 1 April 2023
Ben Charles
Nigel Giles
Augmented profits, associated companies and interaction with QIPs are just some of the issues to consider in advance of the rate change from April, as Nigel Giles and Ben Charles (BDO) explain.
Wholly and exclusively: does a tax motive prevent deductibility?
Ross Birkbeck
Can arrangements designed to reduce a business’s tax bill still be wholly and exclusively for the purposes of its trade? HMRC seems not to think so, writes Ross Birkbeck (Old Square Tax Chambers).
Partnerships and the BlueCrest appeals: doubling down
Andrew Howard
Andrew Howard (Ropes & Gray) examines two Upper Tribunal decisions that go to the heart of the taxation of partnership income.
Reasonable to avoid s 455, but is it an unreasonable charge?
David Whiscombe
David Whiscombe (BKL) reviews the first GAAR Panel decision in favour of the taxpayer and argues that the underlying legislation is long overdue for repeal.
Ask an expert: NRCGT rebasing
Sarah Squires
Sarah Squires (
Old Square Tax Chambers) considers how the
rebasing rules apply to a recent non-resident's plans to sell
UK buy-to-let properties.
The super-deduction and SR allowance: claims on construction projects
Paul Farey
Paul Farey (AECOM) explains why care should be exercised in respect to the relevant contract date and how indirect costs and the timing of expenditure are important in any claim.
Mainly ignored? The main purpose test for SDLT group relief
Helen Coward
Helen Coward (Charles Russell Speechlys) examines the decision in
The Tower One St George Wharf Ltd
concerning the SDLT group relief
anti-avoidance rule.
NCL Investments: an 11-0 taxpayer victory
Angela Savin
Michael Brady
Angela Savin and Michael Brady (KPMG Law) review the impact of a recent
Supreme Court ruling.
Tax and the City review for March 2022
Zoe Andrews
Mike Lane
The Upper Tribunal decision in Royal Bank of Canada and the government’s response to the review of the UK funds regime are among the recent developments reviewed by Mike Lane and Zoe Andrews (Slaughter and May).
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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
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HMRC manual changes: 19 September 2025
Chancellor commits to business rates reform
CIOT warns of ‘unintended complexity’ in APR/BPR draft legislation
Professional bodies analyse draft Finance Bill legislation
Changing the timing of land remediation relief may prove beneficial, says CIOT
CASES
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The Prudential Assurance Company Ltd v HMRC
P Collingwood v HMRC
K (oao Hotelbeds UK Ltd) v HMRC
Other cases that caught our eye: 19 September 2025
SC Arcomet Towercranes SRL
IN BRIEF
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Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
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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