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GROUPS
Budget 2025: the view from the 100 Group Tax Committee
Dominic Mathon
Dominic Mathon (100 Group Tax Committee) reiterates the urgent need for
tax reform to encourage UK investment and boost economic growth.
Bryan Robson: when image and IR35 don’t mix
David Harmer
A recent IR35 tribunal judgment draws a line between services and image rights, and shows the consequences of HMRC errors, writes David Harmer (Markel Tax).
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Tax grouping (part II): capital gains groups
Maddy Potthast
Gavin Little
Continuing the series of articles on corporate tax issues, Gavin Little and
Maddy Potthast (Interpath) explain the rules for capital gains groups and the
pitfalls to watch out for in practice.
Mersey Docks: you’re my wonderwall
Yousuf Chughtai
Davinder Sahota
Davinder Sahota and Yousuf Chughtai (EY) examine a recent FTT decision
which shows how complex and large structures can be considered to function
as plant for capital allowances purposes, even where other premises-like
functions may exist.
Corporate re-domiciliation Panel Report: potential impact on structuring inward bound re-domiciliation
Freddie Schwier
Dominic Foulkes
Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.
Investment into and expansion within the UK: acquisition planning
Helena Kanczula
When structuring a UK acquisition, there are a myriad of tax issues to
consider, as Helena Kanczula (BKL) explains.
Going GloBal: the OECD’s consultation on pillar two
Brin Rajathurai
Murray Clayson
Experts at Freshfields Bruckhaus Deringer examine the OECD's pillar two proposals which could have a fundamental impact on the way all multinationals are taxed.
EU watch: quo vadis, public tax transparency?
Johan Barros
The progress of the European Commission’s proposal for public country by country reporting depends on whether it is regarded primarily as a tax or a company law matter.
Is the DST compatible with the UK’s international obligations?
Rupert Shiers
Jonathan T Stoel
The UK DST in its current form may well breach the UK’s obligations under double tax treaties, international trade law, or both, write Rupert Shiers and Jonathan T Stoel (Hogan Lovells).
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EDITOR'S PICK
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
1 /7
Medpro: better late than never
Stacey Cranmore
2 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
3 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
4 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
5 /7
Understanding the FIG regime
Jo Bateson
6 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
7 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
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
NEWS
Read all
HMRC manual changes: 14 November 2025
Seven tax proposals for growth
Fiscal drag and the additional rate of income tax
Consult on partnership NICs, says APP
HMRC change of policy: VAT on insurance intermediary services
CASES
Read all
Saunders v HMRC
TSI Instruments Ltd v HMRC
Ferrero UK Ltd v HMRC
Uber London Ltd v HMRC
Other cases that caught our eye: 14 November 2025
IN BRIEF
Read all
The new non-dom rules
Meet in the middle: HMRC’s transfer pricing settlement policy
Get the FOTRA out of the UK!
Exclusive purposes
‘Partnership NICs’: the impact on the asset management sector
MOST READ
Read all
HMRC manual changes: 7 November 2025
HMRC v Ducas Ltd
J Boulting v HMRC
Close encounters with close companies (part 2): common issues in practice
Illuminate Skin Clinics Ltd v HMRC