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PRIVATE BUSINESS TAXES
Tax Update 2026
A report by Lexis®+UK Tax
Beyond ten years: rethinking EMI options
Nigel Watson
Claire Withers
Nigel Watson and Claire Withers (Burges Salmon) consider the extension of EMI option terms to 15 years and the practical implications for plan design, legacy options and compliance.
When company law attacks: group relief traps
Sam Pennington
Matthew Rowbotham
Matthew Rowbotham and Sam Pennington (Lewis Silkin) explore the
company law issues on group relief surrenders and the traps that lie in wait.
Ask an expert: LLP to company - navigating incorporation relief
Claire Miles
QuestionMy client runs a business through a limited liability partnership. It was established in this form for legacy reasons many years ago. The business proved successful, and the individual founders took on investment from two companies who now...
An undesirable preference: EIS shares and ‘any’ preferential rights on a winding up
Oliver Twentyman
Many advisers appear to be adopting a contrived and narrow interpretation of
the word ‘preferential’ in an attempt to provide commercial protection to EIS
investors on a winding-up, warns Oliver Twentyman (Azets).
Ask an expert: The BPR dilemma: IHT funding challenges for family-controlled businesses
Ellen Wildig
Sarah Ling
Sarah Ling and Ellen Wildig (Macfarlanes) explore the wider impact
for family-controlled businesses of the upcoming reforms to business
property relief.
Succession planning: the longer-term impact of the Budget on businesses
John Endacott
John Endacott (PKF Francis Clark) explores the background and the current state of succession planning post-Budget.
A third route to exit: tax consequences of continuation fund transactions
May Smith
Emily Szasz
May Smith and Emily Szasz (Freshfields) examine some of the key
tax considerations that arise in relation to the transfer of assets into a
continuation fund.
Structuring following the new rules for IHT business and agricultural property reliefs
Michael Thomas KC
Diversifying ownership will become an increasingly important strategy in
light of the new restrictions to APR and BPR, writes Michael Thomas KC
(Pump Court Tax Chambers).
Ten questions on the Apple judgment
Amaury de Galbert
Dominic Robertson
Does the CJEU’s judgment in
Apple
signify a major shift in tax State aid
cases? Or is
Apple
likely to be a one-off? Amaury de Galbert and Dominic
Robertson (Slaughter and May) investigate.
Go to page
of
115
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’
HMRC v HFFX LLP; Atkins and others v HMRC
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 manual changes: 26 June 2026