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PARTNERSHIPS
Incorporating an LLP: direct tax considerations
Joe Robinson
Harvey Innocent
Joe Robinson and Harvey Innocent (Macfarlanes) explain how LLP members may defer gains when transferring their interests to a company, while highlighting additional complications for corporate members and goodwill.
The (im)practicalities of partnership tax disputes
David Haughey
Sarah Bond
Sarah Bond and David Haughey (Freshfields) discuss some of the practical
challenges which arise in tax disputes involving partnerships and their
members.
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
Craig Kirkham-Wilson
Lauren Trask
Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.
Tax and the City for July 2026
Zoe Andrews
Mike Lane
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May) consider the HFFX decision on LLP deferred remuneration, HMRC’s distributions consultation, the Barclays case on VAT grouping and the credit-management exemption in securitisations.
Uncertain tax treatments consultation: extending uncertainty?
Jack Prytherch
Yousuf Chughtai
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
Ross McGregor
Hannah Manning
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
John Angood
James Hewitt
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).
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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
Effective consultation supports coherent and coordinated tax reform, says CIOT
Chancellor reportedly rejects alignment of CGT and income tax rates
CIOT seeks clarity on interest relief after capital withdrawals
HMRC launch online service for climate change levy returns
Consultation on plastic packaging tax
CASES
Read all
J Smith v HMRC
J Smith v HMRC
The Nigel Blackwell Family Trust and others v HMRC
Other cases that caught our eye: 16 October 2026
HMRC v British Airways plc
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
Victoria Oil & Gas plc v HMRC
Bolt: Supreme Court refuses permission to appeal
Corporate residence: beyond the paperwork
The Nigel Blackwell Family Trust and others v HMRC
Loans to participators: s 455