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Private business taxes
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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
Helen Cox
Gemma Grunewald
Helen Cox and Gemma Grunewald (Fladgate) explain how businesses can expand overseas in a tax-efficient manner.
Cobalt: golden contracts, EZAs and legitimate expectation
Sam Wardleworth
Catherine Robins
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
Mark Baycroft
Martin Mann
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
Anthony Reeves
Neal Todd
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
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
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HMRC manual changes: 12 December 2025
Finance Bill 2026 published
HMRC revise position on VAT grouping and the Skandia judgment
HMRC explain TOMS changes
Welsh Government confirms landfill disposals tax rates
CASES
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Cases of 2025
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
IN BRIEF
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TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
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Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
Tax Journal's 2025 Budget coverage
TSI Instruments and import VAT recovery
Tax in 2025: the good, the bad and the ugly