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RESIDENCE
Welcome to the Hotel United Kingdom: the UK’s proposed re-domiciliation regime
Oliver Walker
Ellie Marques
Check in, but can you check out? Oliver Walker and Ellie Marques (Weil, Gotshal & Manges) explain why companies considering moving to the UK need to think carefully about the UK tax ramifications.
Disregarding SRT days: common sense prevails in Parker
Emily Osborne
‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.
Understanding the FIG regime
Jo Bateson
Jo Bateson (Mercer & Hole) provides a practical guide to the new regime.
Carried interest tax reform: next steps
Bezhan Salehy
Damien Crossley
Damien Crossley and Bezhan Salehy (Macfarlanes) examine the
Government’s latest policy paper.
FA 2025 review: Double remittances
Peter Vaines
Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...
Sajedi: an unwelcome Ramsay surprise
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
Ask an expert: The ‘dog-leg’: a way to fund non-dom divorces while preserving clean capital?
Henry Lowe
Henry Lowe (Mercer & Hole) explores how best to fund a divorce payment
now that the non-dom regime has been abolished.
Ask an expert: Just how enforceable is UK inheritance tax abroad?
Alyssa Haggarty
Claire Weeks
Alyssa Haggarty and Claire Weeks (Maurice Turnor Gardner) consider the
status of the so-called ‘revenue rule’ and the options available to HMRC to
seek assistance in the collection of tax abroad.
Corporate re-domiciliation Panel Report: potential impact on structuring inward bound re-domiciliation
Freddie Schwier
Dominic Foulkes
Under current law, moving an existing group to the UK can be cumbersome. Dominic Foulkes and Freddie Schwier (Davis Polk) explain how the proposed legislative regime could help.
Home and away: how to go non-resident after McCabe
Oliver Marre
The Upper Tribunal’s decision in McCabe shows how difficult it can be to
challenge findings of fact when confronted with multi-factorial tests, writes
Oliver Marre (5 Stone Buildings).
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16
EDITOR'S PICK
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
1 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
2 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
3 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
4 /7
The Orsted ‘tax nothing’
Andrew Page
5 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
6 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
7 /7
ScottishPower and penalties: McKnight sent off
Rupert Shiers
,
Katharine Crossman
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
NEWS
Read all
Finance Bill 2027 published: key measures
International Controlled Transaction Reporting Regulations published
Tax treatment of image rights payments: new draft guidance
SAYE bonus rates increased
ADT: Highlands and Islands exemption
CASES
Read all
Hogan Lovells Cadwalader International LLP v HMRC
HMRC v The Mersey Docks and Harbour Company Ltd
Bottled Science Ltd v HMRC
R (Thomas Holdings Ltd and others) v HMRC
Another case that caught our eye: 13 November 2026
IN BRIEF
Read all
Employees’ expenses
Closing the tax gap: what should taxpayers expect?
Interest withholding tax: a partial solution
Founders’ Relief
Distributions reform: unresolved questions
MOST READ
Read all
Founders’ Relief: a narrow route to 10%
Tax Journal's 2026 Budget coverage
New HMRC withholding tax guidance
Budget 2026: Sovereign immunity - a more considered reform
Distributions reform: unresolved questions