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CORPORATE TAXES
UK corporate re-domiciliation: time to make a move?
Josh Critchlow
Jill Gatehouse
Alison Dickie
Jill Gatehouse, Josh Critchlow and Alison Dickie (Freshfields Bruckhaus Deringer) explore some of the interesting questions about the tax consequences of the proposed regime.
UK loan structures: changes to the anti-hybrid rules
Matthew Mortimer
Kirsten Hunt
Matthew Mortimer and Kirsten Hunt (Mayer Brown) consider the application to UK loan structures of recent changes to the UK’s anti-hybrid rules.
The UK’s new qualifying asset holding company regime
Elena Rowlands
Emily Clark
Ian Zeider
Emily Clark, Elena Rowlands and Ian Zeider (Travers Smith) give an overview of, and their verdict on, the QAHC legislation in the Finance Bill.
SPACs in the City: the tax take
Jenny Doak
Enda Kerin
How friendly is the City’s tax environment when it comes to SPACs? Jenny Doak and Enda Kerin (Weil, Gotshal & Manges) examine what SPAC transactions involve and the key UK tax considerations that can arise.
Tax and the City review for November 2021
Mike Lane
Zoe Andrews
Mike Lane and Zoe Andrews (Slaughter and May) consider Autumn Budget/Finance Bill measures relevant to financial institutions and the latest on international tax reform.
Taxation of loan transfers
David Southern QC
David Southern QC (Field Court Tax Chambers) provides a guide to the tax consequences of loan transfers.
The two-pillar framework: what does the October statement tell us?
Phil Greenfield, Chloe O’ Hara and Giorgia Maffini (PwC) examine the key changes in the Inclusive Framework’s new statement.
Tax and the City review for October 2021
Mike Lane
Zoe Andrews
The impact of the ruling in
Almacantar
, the latest on the economic crime levy and state aid issues are among the developments covered in this month’s review by Mike Lane and Zoe Andrews (Slaughter and May).
The war on holding companies and the return of withholding taxes
Gregory Price
Sarah Ling
BEPS 2.0 and ATAD 3 represent the latest challenge to the tax status of holding companies, renewing focus on issues of substance and withholding taxes, write Gregory Price and Sarah Ling (Macfarlanes).
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Nick Evans
Kate Alexander
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
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
NEWS
Read all
HMRC manual changes: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
The new share for share anti-avoidance
Concerns over the scope of new conduct rules for advisers
HMRC v Sintra Global Inc and another
HMRC manual changes: 9 January 2026
Complex statutory construction: the Court of Appeal’s approach in Tower One