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BTR late than never: SDLT overpayment relief
Helen Coward
‘Overpayment relief is a statutory remedy of last resort.’ Helen Coward (Simmons & Simmons) examines when HMRC can refuse SDLT repayment claims – and when they cannot.
Complex statutory construction: the Court of Appeal’s approach in Tower One
Cristy Ajediti
Helen Coward
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
Trouble in store for the Sehgals
John Shallcross
John Shallcross (Blake Morgan) examines the counter-intuitive result in a mixed property SDLT decision.
SDLT and residential properties: mix up with a fix up
Max Schofield
The case of
Mudan
has likely closed the door on claims that unsound
properties qualify for non-residential rates of SDLT, writes Max Schofield
(Devereux Chambers).
Property taxation reimagined
Andrew Dixon OBE
Andrew Dixon OBE, founder of Fairer Share, makes the case for the
introduction of a proportional property tax.
Lifecycle of a transaction: managing VAT risk
Richard Woolich
In our continuing series on the lifecycle of a transaction, Richard Woolich
(DLA Piper) examines the VAT implications of both buying property directly
and acquiring the shares of a property-owning company.
Scatola: 20 years to raise s 75A discovery assessments
Sinisa Butina
Angela Savin
Angela Savin and Sinisa Butina (KPMG) examine the basis of the Upper
Tribunal’s reasoning in
Scatola
and the broader ramifications for taxpayers
seeking certainty and finality to their SDLT affairs.
The Reserved Investor Fund: a practitioner guide
Paul Shaw
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
Sajedi: an unwelcome Ramsay surprise
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) explores some difficulties resulting from the tribunal’s purposive interpretation in a recent case.
Lessons on SDLT overpayment relief from BTR Core Fund JPUT
John Shallcross
John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.
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49
EDITOR'S PICK
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
1 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
2 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
3 /7
Estoppel and abuse of process in VAT
Claire Logan
4 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
5 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
6 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
7 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
NEWS
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New PM Andy Burnham appoints Healey as Chancellor and announces VAT cut for domestic electricity
Loan charge settlement scheme: regulations and guidance published
The Taxation (Energy and Vehicles) Act 2026 receives royal assent
Bank levy definitions consultation
Government shelves offshore interest tax reform after consultation
CASES
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M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
Other cases that caught our eye: 24 July 2026
St Patrick’s International College Ltd and others v HMRC
IN BRIEF
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Directors’ liability: tax schemes
BlueCrest: the impact for asset managers
When Ramsay does not rescue HMRC
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
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Tax and the City for July 2026
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Tax Journal's Legislation day 2026 coverage