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RESIDENCE
Welcome to the Hotel United Kingdom: the UK’s proposed re-domiciliation regime
Ellie Marques
Oliver Walker
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: options for taxing wealth
Dom Rothbarth
1 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
2 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
3 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
4 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
5 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
6 /7
The new Securities Transfer Tax: business as usual?
Georgina West
7 /7
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
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
NEWS
Read all
Tax Journal authors for August and September
Labour conference backs wealth and windfall taxes, as Burnham pledges national care service
Welsh rates of income tax: HMRC report
New VAT guidance on partnership details
Further Scottish visitor levy changes
CASES
Read all
Jumpman Gaming Ltd v HMRC
K Poznic v HMRC
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Other cases that caught our eye: 2 October 2026
Environmental Services Ltd v HMRC
IN BRIEF
Read all
Loans to participators: s 455
Modernising the taxation of distributions
HMRC’s new anti-avoidance information notice powers
Substantial
Modernising the taxation of distributions: why now?
MOST READ
Read all
Consultation tracker
Modernising the taxation of distributions: why now?
HMRC powers and the taxpayer relationship: when is enough, enough?
Sir J Griffin v HMRC
Environmental Services Ltd v HMRC