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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
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
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
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Welsh tax Bill proposes repayment powers and LTT changes
Voluntary payrolling extended to accommodation and loans
Clarification sought on IHT exemption for charitable trusts
‘No separate VAT rules for cryptoassets’, HMRC say
CBAM: draft default emissions values published
CASES
Read all
ScottishPower (SCPL) Ltd and others v HMRC
T Bunting v HMRC
Brants Bridge Ltd and another v HMRC
Other cases that caught our eye: 23 October 2026
J Smith v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
The Nigel Blackwell Family Trust and others v HMRC
Chancellor reportedly rejects alignment of CGT and income tax rates
Incorporating an LLP: direct tax considerations
One minute with... Helen Miller
J Smith v HMRC