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PRIVATE BUSINESS TAXES
Wealth tax possibilities
Philip Simpson KC
It cannot be ruled out that Labour’s current policy will not change, writes Philip Simpson KC (Old Square Tax Chambers).
The CIR and related party guarantees: a case study for a privately owned UK group
Robert Langston
Robert Langston (Saffery) provides a practical case study on the operation
of the corporate interest restriction where related party guarantees and
withholding tax issues are involved.
Tax aside? Private investment fund side letters
Deepesh Upadhyay
Benjamin Shem-Tov
Ben Jones
Ben Jones, Deepesh Upadhyay and Benjamin Shem-Tov (Eversheds
Sutherland) examine the increasing use of side fund letters in a private
investment funds context and the associated most favoured nations process.
Tax and the energy sector: what’s in store for 2024?
Deeksha Rathi
Edward Milliner
Deeksha Rathi and Edward Milliner (Slaughter and May) reflect on recently announced changes in an area faced with global instability, net zero goals and political change.
The Scottish Budget 2024/25: widening the divergence
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) report on Scotland’s latest Budget, which introduces a new ‘advanced’ rate of income tax.
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).
Single supply and VAT exemption for financial services: insights from JPMorgan
Anastasia Nourescu
Naima Khalid
Naima Khalid (EY) and Anastasia Nourescu (Stewarts) consider the impact
of the recent decision in JPMorgan.
School fee planning: back in the Spotlight
Gordon W Buist
Gordon W Buist (EQ Accountants) examines the impact of the settlements legislation on school fee planning arrangements.
Resolving large business tax disputes: what more should be done?
Stephen Daly
Stephen Daly (King’s College London) reports findings from a recent study suggesting the need for greater transparency and training at HMRC, as well as a rebalancing of the tax administration framework.
HMRC’s evolving approach to tax compliance for the largest businesses
Nicole Newbury
HMRC’s large business director, Nicole Newbury, outlines the department’s approach, including priority areas of focus and how it is evolving to reflect wider changes in the economy and customers’ circumstances.
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for January
HMRC manual changes: 30 January 2026
Tax bodies back Lords concerns over IHT reforms, including ‘huge’ burden on PRs
Finance Bill 2026 amendments
PAYE changes for employment expenses and gift aid relief
CASES
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Nimbus: The Disability Consultancy Service Ltd v HMRC
Delphi Derivatives Ltd (in liquidation) v HMRC
Other cases that caught our eye: 30 January 2026
HMRC v MedPro Healthcare
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
COP 9 and serious tax fraud: HMRC’s tougher approach
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
Transfer Pricing Guidelines for Compliance
A Budget for its times? The Scottish Budget 2026/27