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Anti avoidance
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Anti avoidance
ANTI AVOIDANCE
The new 40% first year allowance
Paul Farey
Paul Farey (AECOM) reviews the new rules and HMRC’s guidance.
Mixed member partnerships: anti-avoidance rules
A back to basics guide from Lexis®+ UK Tax.
Deductions after AD Bly: a shortcut for remuneration or pension provision?
Aparna Nathan
The Court of Appeal has clarified when remuneration and pension provision will satisfy the ‘wholly and exclusively’ test – and when a tax avoidance purpose will defeat a deduction, writes Aparna Nathan KC (Devereux Chambers).
An increasingly tough stance on behavioural penalties
Sophie Rhind
Elvira Colomer Fatjo
Sophie Rhind and Elvira Colomer Fatjo (Macfarlanes) consider how recent decisions and proposed reforms are reshaping the behavioural penalty landscape.
COP 9 and serious tax fraud: HMRC’s tougher approach
Simon York CBE
HMRC are adopting a tougher stance with those who continue to deliberately
mislead or refuse to cooperate, despite being in the COP 9/CDF process,
writes Simon York CBE (Deloitte).
Complex statutory construction: the Court of Appeal’s approach in Tower One
Helen Coward
Cristy Ajediti
Helen Coward and Cristy Ajediti (Simmons & Simmons) explain why Tower One is another warning on the risks of complex, tax-driven arrangements.
Share reorganisations: new anti-avoidance rules explained
Peter Morley
Jamie Robson
The Autumn Budget 2025 tightens anti-avoidance rules for share
reorganisations. Peter Morley and Jamie Robson (Pinsent Masons) explain
what tax professionals need to be aware of.
Contentious tax in 2025
Adam Craggs
Liam McKay
Adam Craggs & Liam McKay (RPC) report a year marked by tighter
procedural frameworks, clarifying case law and an intensified HMRC focus on
both avoidance and criminal activity.
The 2025 loan charge review and Government response: the final chapter?
David Pett
All but one of the loan charge review’s ‘hard’ recommendations have been
accepted. David Pett (Temple Tax Chambers) assesses both the review and
the Government’s response – and considers the implications for affected
taxpayers and the new settlement opportunity.
Close encounters with close companies (part 2): common issues in practice
Ross McGregor
Hannah Manning
There is a myriad of anti-avoidance legislation which must be carefully
considered throughout the lifecycle of a close company. Hannah Manning
and Ross McGregor (Travers Smith) explain how to avoid some of the
common pitfalls.
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225
EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Consultation launched on extending UTT regime
Finance Bill completes parliamentary stages
Regulations set 2026/27 NIC rates and extend veterans relief
Further NIC re-rating provisions for 2026/27
Voluntary NIC window for those abroad closes soon
CASES
Read all
Muller UK and Ireland Group LLP and others v HMRC
Countrywide Partners Ltd v HMRC
S Kamal v Tax Policy Associates Ltd and another
Other cases that caught our eye: 20 March 2026
CooperVision Lens Care Ltd v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
CooperVision Lens Care Ltd v HMRC
Consultation tracker
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Transactions in Securities counteraction notices
HMRC expected to delay tax agent registration for financial services