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CORPORATE TAXES
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.
Tax on SMEs in 2024
Andrew Constable
While 2024 has not exactly been plain sailing for SMEs, the tax related developments have not been as radical or fundamental as might have been feared, writes Andrew Constable (Mercer & Hole).
Insuring M&A tax risks: practical considerations for buyers
Shayaan Zaraq Bari
Nicholas Gardner
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining
W&I insurance with other tools may help bridge any gaps in tax risk coverage
and maximise protection for buyers.
The Upper Tribunal’s ruling in Gould on interim dividends
Dominic Stuttaford
Aiden Hepworth
Dominic Stuttaford and Aiden Hepworth (Norton Rose Fulbright) assess the
practical impact of the Upper Tribunal’s decision in Gould.
Tax and the City review for November 2024
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine the impact of the Autumn Budget and some recent tribunal decisions on the financial sector.
Corporation tax rate complexities for corporate LLP members
Emma Rawson
The corporation tax rates rules can be complex. Emma Rawson (ATT) looks at the particular difficulties facing corporate members of LLPs.
10 questions on Uncertain Tax Treatment
Abigail McGregor
Steven Porter
Steven Porter and Abigail McGregor (Pinsent Masons) consider the UTT
regime after two years of operation.
Divide and conquer: the partition demerger story
Matt Cummings
Colin Askew
Alisha Kouser
Untangling a business from a group (or single entity) in a tax neutral fashion
takes time and care. Colin Askew, Matt Cummings and Alisha Kouser
(Eversheds Sutherland) provide a case study considering the tax issues on a
partition demerger.
Hybrids and dual inclusion income: are we there yet?
Richard Milnes
Fehzaan Ismail
Richard Milnes and Fehzaan Ismail (EY) assess the concept of dual inclusion
income under the UK hybrid provisions following a prolonged period of
iterative change.
No joy for JTIAC: an extension of the unallowable purpose principle
Constantine Christofi
The last in a trilogy of recent Court of Appeal cases on ‘unallowable purpose’ has seemingly extended its ambit yet further, writes Constantine Christofi (EY).
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301
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 manual changes: 12 September 2025
Secondary NICs on partnerships an equitable option, says report
Conveyancing and SDLT ‘advice’ in the spotlight
ATT outlines concerns on IHT pensions proposals
Scottish aggregates tax framework brought into force
CASES
Read all
SC Arcomet Towercranes SRL
Other cases that caught our eye: 12 September 2025
Lexgreen Services Ltd v HMRC
Elphysic Ltd and others v HMRC
W Tinkler v HMRC
IN BRIEF
Read all
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
Will Ms Rayner face HMRC penalties?
Loans to participators: s 455
Closing the tax gap: HMRC’s approach to ‘legal interpretation disputes’
MOST READ
Read all
Lexgreen Services Ltd v HMRC
Reshuffle at the Treasury
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
Elphysic Ltd and others v HMRC