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VAT
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The VAT review for July 2026
Gary Barnett
Karen Bannister
In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.
Estoppel and abuse of process in VAT
Claire Logan
Claire Logan (Grant Thornton) explains why estoppel and abuse of process
are increasingly relevant in VAT disputes and how they can materially affect
how cases are argued and resolved.
Queenscourt: a dip in legal certainty
James Hurst
Fabian Barth
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
The UK’s tax certainty problem
Jenny Batchelor
Ahmed Mobasshir
The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).
Steering EV tax strategy in the right direction
Daria Nikitina
Simon Down
Benefit in kind rates remain attractive for electric vehicles, but are only part of the picture. Simon Down and Daria Nikitina (Deloitte) explain why employers should adopt a total cost of operation approach to fleet strategy.
The VAT review for June 2026
Katie Oliver
Gary Barnett
This month’s review by Katie Oliver and Gary Barnett (Simmons &
Simmons) covers VAT and transfer pricing after Stellantis Portugal, input tax
repayment disputes and a reminder that overcharged VAT cannot normally be
reclaimed directly from HMRC by the customer.
International review for May 2026
Tim Sarson
Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.
UK to UK transfer pricing: what the recent changes mean for VAT
Lyndon Firth
Swati Thapa
The removal of UK-to-UK transfer pricing will shift VAT to the forefront of domestic intra-group compliance, write Lyndon Firth and Swati Thapa (BDO).
Lycamobile UK: guaranteed availability, guaranteed VAT
Julius Berling
Liesl Fichardt
Liesl Fichardt and Julius Berling (Quinn Emanuel) assess the Upper Tribunal ruling in Lycamobile and its implications beyond telecoms.
Strike-out!
Glyn Edwards
Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.
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249
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 confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC confirm transitional approach to Pillar Two filing penalties
HFFX: the widening reach of miscellaneous income