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Anti avoidance
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Anti avoidance
ANTI AVOIDANCE
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.
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
Liam McKay
Adam Craggs
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
Hannah Manning
Ross McGregor
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.
Legislating against promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines the draft legislation proposing Universal Stop Regulations and Promoter Action Notices, raising concerns over their breadth and lack of safeguards.
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.
FA 2025 EOT rules and the impact on valuations
Ritchie Tout
The recent changes to the Employee Ownership Trust rules bring the regime
back to its intended purpose – and may impact many valuations, writes
Ritchie Tout (Azets).
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines recent Government
proposals which, he says, leave little doubt that tax avoidance, like tax evasion,
is to be regarded as a criminal activity.
EIS disqualifying arrangements: jumping through the Hoopla
Tom Wilde
Tom Wilde (Shoosmiths) examines an Upper Tribunal decision that raises some interesting points for EIS practitioners.
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225
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
The new share for share anti-avoidance
HMRC v Sintra Global Inc and another
Concerns over the scope of new conduct rules for advisers
Complex statutory construction: the Court of Appeal’s approach in Tower One
HMRC manual changes: 9 January 2026