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Tax policy & administration
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Tax policy & administration
TAX POLICY ADMINISTRATION
GfC 13 and the filing position: nothing to see here?
Angela Savin
Andrew James
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
Across the pond: comparing US and UK M&A tax protections
Richard Liu
Simon Skinner
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
How to interpret double tax treaties
Kyle Rainsford
Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard)
revisits the basic principles of interpreting tax treaties in the UK.
The future of international tax reform
Philip Baker KC
The prognosis for international tax reform does not look good, writes
Philip Baker KC (Field Court Tax Chambers).
The curious case of Uncertain Tax Treatments
Jack Prytherch
Yousuf Chughtai
HMRC’s newly published materials raise important questions about
how taxpayers are engaging with the UTT regime in practice, writes
Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
The ICTS: a new chapter in transfer pricing compliance
Amy Clarke
Andrew Stewart
The International Controlled Transaction Schedule is expected to be
introduced in the UK in the foreseeable future. Andrew Stewart and
Amy Clarke (BDO) explain how to prepare.
AI in a new tax (3.0) world
Conrad Young
Tax technology adviser Conrad Young considers AI's rapidly increasing role for tax authorities and tax market participants.
Tax and the City review for September 2025
Zoe Andrews
Mike Lane
The tribunal decision in
Currys
on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
Secondary legislation: the importance of statutory instruments
Alan Evans CB
Alan Evans CB, HMRC’s General Counsel and Director General of the
department’s Legal Group, discusses an often overlooked but crucial part to
the running of the tax system.
The Temporary Repatriation Facility opportunity
Alice Pearson
The Temporary Repatriation Facility could create significant tax savings
for some. Alice Pearson (Mercer & Hole) highlights some practical
considerations and areas of complexity.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 10 October 2025
Government no closer on wealth tax
ATT launches MTD ‘digital readiness tips’ for agents
R&D claims down but support remains stable
Reactivating clients’ self-assessment accounts
CASES
Read all
GW Martin & Co Ltd and another v HMRC
A Weis v HMRC
Other cases that caught our eye: 10 October 2025
Isle of Wight NHS Trust v HMRC
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
GfC 13 and the filing position: nothing to see here?
Isle of Wight NHS Trust v HMRC
Legislating against promoters of marketed tax avoidance scheme