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PARTNERSHIPS
Uncertain tax treatments consultation: extending uncertainty?
Yousuf Chughtai
Jack Prytherch
Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans
to widen the UTT regime and the practical implications for taxpayers.
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Henry Bennett-Gough
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in
Boston Consulting Group
and its implications for mixed member LLP structures.
Mixed member partnerships: anti-avoidance rules
A back to basics guide from Lexis®+ UK Tax.
Close encounters with close companies (part 1): definitions and concepts
Hannah Manning
Ross McGregor
In the first of two articles examining the close companies rules, Hannah
Manning and Ross McGregor (Travers Smith) explain why it should not be
assumed that a company is not close without looking carefully at the relevant
legislation.
Losses and major changes in the trade or business
James Hewitt
John Angood
John Angood and James Hewitt (BDO) provide a back to basics guide.
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).
The CBAM trilemma
Joshua Stevens
The UK’s Carbon Border Adjustment Mechanism launches in January 2027.
Joshua Stevens (Pump Court Tax Chambers) explains what’s proposed – and
why it risks exacerbating trade tensions at a time of rising protectionism.
Partnerships and SP D12
Alex Sim
Tanja Velling
A back to basics guide on SP D12 and CGT for partnerships, by Alex Sim and
Tanja Velling (Slaughter and May).
Taking an interest in partnerships: examining BCG v HMRC
David Haughey
David Haworth
David Haworth and David Haughey (Freshfields Bruckhaus Deringer) review the implications of the FTT’s decision for those advising on partnership equity/incentivisation arrangements or on mixed member partnership arrangements.
The taxation of SMEs in 2023
David Whiscombe
Disputes over partnerships, goodwill, distributions and VAT were among some of this year’s key points of interest for SMEs, writes David Whiscombe (BKL).
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
IHT replacement property relief restrictions
One minute with… Jon Claypole