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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.
The VAT review for May 2026
Gary Barnett
Karen Bannister
Karen Bannister and Gary Barnett (Simmons & Simmons) review recent VAT developments, including
Colchester Institute, Boehringer Ingelheim
and input tax recovery on statutory expenditure.
The VAT review for April 2026
Gary Barnett
Karen Bannister
Karen Bannister and Gary Barnett (Simmons & Simmons) review recent decisions on VAT exemptions for securitisation vehicles and in-game currencies, the treatment of loyalty points, and the reduced rate for public EV charging.
Penalty suspension
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
So much ‘noise’: HMRC’s evolving approach to corporate compliance
Karmjit Mader
Vicky Topps
HMRC’s increasing focus on upstream compliance and a more data-led, riskbased
approach marks a clear shift away from the traditional enquiry cycle,
as Vicky Topps and Karmjit Mader (KPMG) explain.
Headless chickens: Morrisons and the FTT’s supervisory jurisdiction
Yousuf Chughtai
Jack Prytherch
The only complete solution to the procedural nightmare potentially faced by taxpayers is to expand the FTT’s powers to consider public law issues, write Jack Prytherch and Yousuf Chughtai (Osborne Clarke).
The VAT review for March 2026
Gary Barnett
Gary Barnett (Simmons & Simmons) reviews recent VAT developments, including the Upper Tribunal’s decision in Lycamobile and CJEU guidance on statutory payments.
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248
EDITOR'S PICK
Spare us the cUTTer
Nick Thornton
1 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
2 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
3 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
4 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
5 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
6 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
7 /7
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
NEWS
Read all
Foreign Permanent Establishment exemption to be made mandatory
Chancellor announces package of road fuel measures
Quarterly advisory fuel rates published
New Isle of Man social security agreement signed
Streeting proposes CGT equalisation in ‘wealth tax’ plan
CASES
Read all
Queenscourt Ltd v HMRC
Re Waldorf Production UK plc
H Gwyn-Jones v HMRC
Other cases that caught our eye: 29 May 2026
HC-One No 1 Ltd v HMRC
IN BRIEF
Read all
HMRC clarify CIS financing positions
TP adjustments and VAT: lessons from Stellantis Portugal
Updating the obsolete
The growing problem of the personal allowance phase down
Situs: loan notes
MOST READ
Read all
HC-One No 1 Ltd v HMRC
Take 3.9 TV Partnership and others v HMRC
When Homer nods: the rise of the Inco principle in tax
The growing problem of the personal allowance phase down
Trustees IHT exposure from 6 April 2025