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Tax policy & administration
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Tax policy & administration
TAX POLICY ADMINISTRATION
Tax Update day: a flexible friend?
Chris Sanger
A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.
HFFX: the widening reach of miscellaneous income
Tom Margesson
Elena Rowlands
Ian Zeider
A low bar for ‘source’? Elena Rowlands, Tom Margesson and Ian Zeider (Travers Smith) explain the Supreme Court’s decision in HFFX and its significance for LLP member remuneration.
The VAT review for July 2026
Gary Barnett
Karen Bannister
In this month’s review, Karen Bannister and Gary Barnett (Simmons & Simmons) examine developments on VAT grouping and overseas entities, securitisation servicing after loan transfers, and the uncertain boundary between single and multiple supplies.
The new carried interest regime: implications for non-residents working in the UK
Alex Ereira
Aron Joy
The carried interest reforms create substantial compliance burdens and may
expose internationally mobile investment managers to double taxation, write
Aron Joy and Alex Ereira (Weil, Gotshal & Manges).
Mandatory tax adviser registration: clearer, but not clear enough
Emma Rawson OBE
Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new
Mandatory Tax Adviser Registration Manual.
Loans to participators: where are we now?
Paul Townson
Chris Holmes
Paul Townson and Chris Holmes (BDO) examine the recent changes
which are making the loans to participators regime more onerous for close
companies and advisers.
Queenscourt: a dip in legal certainty
James Hurst
Fabian Barth
Fabian Barth and James Hurst (Johnston Carmichael) consider the implications for single and multiple supplies and legitimate expectation arguments.
The tax gap and the limits of compliance
Ray McCann
Small businesses remain HMRC’s principal compliance target, but tackling non-compliance will require more than enforcement, argues Ray McCann.
Disregarding SRT days: common sense prevails in Parker
Emily Osborne
‘A victory for common sense’. Emily Osborne (Fladgate) reviews an FTT decision on exceptional circumstances and transit days under the Statutory Residence Test.
The UK’s tax certainty problem
Jenny Batchelor
Ahmed Mobasshir
The UK’s legal framework offers statutory and non-statutory clearances, CCMs, APAs and the forthcoming Advance Tax Certainty Service, but these mechanisms fall short in practice, write Jenny Batchelor and Ahmed Mobasshir (Ryan).
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607
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
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
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
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
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC v HFFX LLP; Atkins and others v HMRC
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC manual changes: 26 June 2026