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CORPORATION TAX
Pillar Two and the GloBE rules
James Burton
Ellen Birkemeyer
Mitchell Fraser
Naomi Lawton
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
Nigel Giles
Ben Charles
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
Mike Lane
Zoe Andrews
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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198
EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
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
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Requirements for forthcoming pensions IHT changes
Loan charge settlement scheme: regulations and guidance published
One minute with... Tim Gummer