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PRIVATE BUSINESS TAXES
Amendments to the 2019 loan charge: work in progress
David Southern QC
David Southern QC (Temple Tax Chambers) examines where things stand following publication of the first batch of draft legislation that restricts the loan charge.
HMRC v A Naghshineh
Farming losses and the reasonable expectation of profits tests for sideways loss relief
Lifecycle of a business: international expansion
Gemma Grunewald
Helen Cox
Helen Cox and Gemma Grunewald (Fladgate) explain how businesses can expand overseas in a tax-efficient manner.
Cobalt: golden contracts, EZAs and legitimate expectation
Catherine Robins
Sam Wardleworth
Catherine Robins and Sam Wardleworth (Pinsent Masons) review an interesting Upper Tribunal decision on the test for trading, 'golden contracts' and the availability of enterprise zone allowances and legitimate expectation.
2019 review: a year of uncertainty for SMEs
Martin Mann
Mark Baycroft
Martin Mann and Mark Baycroft (Markel Tax) reflect on the growing
compliance burden and whether valuable reliefs will continue to be available
in their current form.
How to handle the structures and buildings allowance
John Lovell
John Lovell (Lovell Consulting) provides some practical guidance on the new allowance following publication of HMRC's guidance.
Lifecycle of a business: financing and growth
Neal Todd
Anthony Reeves
Neal Todd and Anthony Reeves (Fladgate) consider some of the funding methods open to a business trading as a limited company.
Entrepreneurs’ relief: the qualifying beneficiary requirement
Sam Brodsky
According to a recent tribunal decision, the qualifying beneficiary test entrepreneurs' relief need only be met at the time of a disposal of settlement business assets. Sam Brodsky (Gray's Inn Tax Chambers) reports.
Sale of goodwill
Peter Vaines
HMRC's views on goodwill and the sale of businesses were roundly rejected in a recent tribunal decision.
Comment: Why the loan charge is unfair
Keith Gordon
The loan charge has driven a coach and horses through the statutory safeguards, writes barrister Keith Gordon (Temple Tax Chambers).
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115
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC confirm all SA109 taxpayers exempt from MTD until April 2027
CBAM emissions and verification draft regs: consultation
BPR and APR apportionment tool
GfC18: VAT place of supply in oil and gas sector
E-invoicing confusion highlighted by HMRC research
CASES
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CATS North Sea Ltd v HMRC
Bilfinger Salamis UK Ltd v HMRC
Other cases that caught our eye: 17 April 2026
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
IN BRIEF
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Tax advisers: sanctionable conduct
Section 171A elections
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
MOST READ
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J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
HMRC v Colchester Institute Corporation
Staggered roll-out for mandatory tax adviser registration
Consultation tracker