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CORPORATE TAXES


No joy for JTIAC: an extension of the unallowable purpose principle premium
Card image 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).
26 June 2024
The CIR and related party guarantees: a case study for a privately owned UK group premium
Card image Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation of the corporate interest restriction where related party guarantees and withholding tax issues are involved.
24 April 2024
A cautionary tale: how to fail to show accounts are GAAP-compliant premium
Card image Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the recent decision in Barclays Bank Plc v HMRC.
18 April 2024
The impact of Pillar Two on tax risk apportionment for a corporate sale premium
Card image Anne Powell
Anne Powell (Bryan Cave Leighton Paisner) considers how our historic experience of tax covenants steer us to resolve new Pillar Two risks.
20 March 2024
Writing off a loan: the unallowable purpose trap premium
Card image Mark Whitehouse
Card image Mairead Cummins
Tax Journal’s recent coverage of the Keighley case has largely focused on connected companies issues. Here, Mark Whitehouse and Mairead Cummins (PwC) focus on the other key issue in that case: the ‘gateway test’ for the deductibility of loan relationship debits.
20 March 2024
Difficult choices: disguised remuneration in the context of corporate insolvency premium
Card image Jon Preshaw
Card image Ben Proctor
Significant employment tax charges can arise in certain insolvency situations where there was never an intention for rewards to be provided in connection with employment, write Jon Preshaw and Ben Proctor (Jon Preshaw Tax).
14 February 2024
Tax and the City review for February 2024 premium
Card image Zoe Andrews
Card image Mike Lane
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).
7 February 2024
Tax clouds on the Horizon for the Post Office? star
Card image Heather Self
Heather Self (Blick Rothenberg) considers the tax issues surrounding compensation payments made by the Post Office to subpostmasters.
17 January 2024
On purpose: developments in the main purpose test premium
Card image Oliver Walker
Card image Akash Mehta
Oliver Walker and Akash Mehta (Weil, Gotshal & Manges) consider the current status of the TCGA 1992 s 137 main purpose test.
17 January 2024
The move to permanent full expensing premium
Card image 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.
10 January 2024
EDITOR'S PICKstar
NEWSRSS Read all
CASESRSS Read all
T Bunting v HMRC
21 October 2026
J Smith v HMRC
14 October 2026
IN BRIEFRSS Read all
MOST READ Read all
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