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CORPORATE TAXES
Tax and the City review for February 2024
Mike Lane
Zoe Andrews
The Court of Appeal’s decision in
Dolphin Drilling
and consultation responses on the modernisation of transfer pricing, DPT and PEs are among the recent developments in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
Tax clouds on the Horizon for the Post Office?
Heather Self
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
On purpose: developments in the main purpose test
Akash Mehta
Oliver Walker
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the
current status of the TCGA 1992 s 137 main purpose test.
The move to permanent full expensing
Jasmine Kaur
The move to permanent full expensing marks a change in UK corporate tax strategy, writes Jasmine Kaur, Head of Capital Allowances at HM Treasury.
2023: a parting glance in the rear view mirror for corporate tax practitioners
Gerald Montagu
It is in the tribunals and courts that many of the more interesting developments have taken place during 2023, writes Gerald Montagu (Gide).
New R&D scheme misses the point
Justine Dignam
The latest R&D reforms were said to simplify the tax regime and encourage
business investment. The reality though is more complexity, writes
Justine Dignam (Markel Tax).
The resurgence of crown preference: the dog in the manger
Eloise Walker
Are we seeing a slow return to Crown preference (including for corporation tax) by the back door, asks Eloise Walker (Pinsent Masons).
Unlawful distributions: why knowledge matters
Helen Coward
Lewis Currie
Helen Coward and Lewis Currie (Charles Russell Speechlys) consider the
consequences of unlawful distributions by UK companies, including the tax
pitfalls to avoid.
The BlueCrest trilogy
Andrew Howard
Same conclusion but different reasoning. Andrew Howard (Ropes & Gray) reviews the recent Court of Appeal judgment on tiered limited partnerships, profit allocation and interest deductibility.
Transfer pricing and intangibles: are all the issues priced in?
Alex Rigby
James Anderson
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
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302
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem