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Pensions & investments
PENSIONS INVESTMENTS
The Reserved Investor Fund: a practitioner guide
Paul Shaw
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
Ask an expert: CGT and excluded settlors: reimbursement risks for trustees post-April 2025
Carolyn Steppler
Alice Martin
Alice Martin and Dr Carolyn Steppler (Charles Russell Speechlys) explain why excluding a settlor and spouse may not prevent CGT attribution after April 2025, and what reimbursement risks trustees must manage.
Non-doms post-Budget: where are we now?
Helen McGhee
Lynnette Bober
Helen McGhee and Lynnette Bober (Joseph Hage Aaronson) provide an
overview of the new rules and highlight some key points to watch.
Pillar Two and funds: there is no panacea
Alistair Godwin
Andrew Yeomans
Alistair Godwin and Andrew Yeomans (EY) review three areas of complexity
that present challenges to asset managers.
VAT and management of SIFs: a new world post-Brexit?
Giles Salmond
Giles Salmond (Stewarts) assesses the likely impact of Advocate General
Kokott’s opinion in the Dutch pension fund cases.
The new Reserved Investor Fund: what we know so far
Melville Rodrigues
Naomi Lawton
Melville Rodrigues (Apex Group) and Naomi Lawton (Allen & Overy)
provide an overview of the new regime that offers additional flexibility and
plugs a gap in the UK’s existing fund range.
Tax and the City review for March 2024
Zoe Andrews
Mike Lane
Keighley
on the loan relationship rules,
Clipperton
on purposive construction
and the introduction of the Reserved Investor Fund are among the
developments examined by Mike Lane and Zoe Andrews (Slaughter and May).
The new pension tax changes: a practical guide
Elsa Littlewood
Chris Holmes
Chris Holmes and Elsa Littlewood (BDO) examine the overhaul of the pensions tax rules in the Finance Bill.
What should be done about carried interest?
Heather Self
Most would probably agree that the current rate of tax on carried interest is too low. But whatever solution is adopted, a balance needs to be struck between complexity and ‘fairness’, writes Heather Self (Blick Rothenberg).
PE funds and master holding companies: traps for the unwary
James Shorland
James Shorland (Alvarez and Marsal) explores some of the unintended UK tax consequences of master holdco structures on portfolio companies of private equity funds.
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126
EDITOR'S PICK
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
1 /7
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
,
Martin Verrall
2 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
3 /7
The Orsted ‘tax nothing’
Andrew Page
4 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
5 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
6 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
7 /7
From sovereign immunity to sovereign tax status
Tom Margesson
,
Elena Rowlands
Founders’ Relief: a narrow route to 10%
Hannah Magee
,
Charlotte Senior
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
NEWS
Read all
Founders’ Relief: tax bodies warn over eligibility and technical traps
LISA withdrawal charge reduced
HMRC confirm VAT treatment of public EV charging
Donated medicines to be zero-rated
New HMRC withholding tax guidance
CASES
Read all
N Powell v HMRC
Inngrays Ltd v HMRC
Portsmouth City Council v HMRC
Other cases that caught our eye: 6 November 2026
Abbey Group Ltd v HMRC
IN BRIEF
Read all
Distributions reform: unresolved questions
CGT: irrecoverable loans
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
MOST READ
Read all
Budget 2026: Sovereign immunity - a more considered reform
Tax Journal's 2026 Budget coverage
Consultation tracker
Government declines to expand land remediation relief
Budget 2026: the tax measures