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APPEALS
The Orsted ‘tax nothing’
Andrew Page
Andrew Page OBE (formerly HMRC) argues that the denial of relief for
windfarm survey costs exposes a gap between the rules for capital allowances
and intangible assets.
Tax and the City for September 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent decisions
on treaty interpretation, deeming provisions and group litigation orders,
alongside HMRC’s latest performance figures.
The new taxpayer duty to correct inaccuracies: an obligation lacking clear boundaries
Peter North
Rob Sharpe
An obligation to correct tax return inaccuracies is coming. Rob Sharpe and
Peter North (Cleary Gottlieb) examine the mechanics and some interpretative
uncertainties.
Home, a loan: the Court of Appeal’s ruling in Elborne
Louis Triggs
Louis Triggs (Pump Court Tax Chambers) examines the landmark Elborne decision and its wider significance for IHT, trusts and statutory interpretation.
TOMS: a narrower road after Bolt Services
Dr Michael Taylor
Dr Michael Taylor (PwC) explains how the Court of Appeal’s Bolt Services decision narrows the scope of the Tour Operators’ Margin Scheme.
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
Craig Kirkham-Wilson
Lauren Trask
Form over influence? Constantine Christofi, Craig Kirkham-Wilson and Lauren Trask (EY) examine the Supreme Court’s decision in BlueCrest and what it means for Conditions A and B of the salaried members rules.
Sintra, Hall and the reshaping of HMRC’s burden of proof
Julius Konstantin Berling
Liesl Fichardt
Emily Au
Who proves what? Liesl Fichardt, Emily Au and Julius Konstantin Berling (Quinn Emanuel) set out how penalty appeals now divide the burden between HMRC and the taxpayer – and why the line between the two is far from settled.
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Jade Du Berry
Alan Rafferty
Ollie Winters
The High Court has confirmed that HMRC do not have a veto over
restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank)
examine the implications of Waldorf, including HMRC’s constitutional
arguments, the treatment of tax losses and the evolving approach to cross-class
cram downs.
The VAT review for June 2026
Katie Oliver
Gary Barnett
This month’s review by Katie Oliver and Gary Barnett (Simmons &
Simmons) covers VAT and transfer pricing after Stellantis Portugal, input tax
repayment disputes and a reminder that overcharged VAT cannot normally be
reclaimed directly from HMRC by the customer.
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Rebecca Seeley Harris (Re Legal Consulting) examines the potential grounds on which HMRC could appeal the judgment.
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EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
HMRC name 196 deliberate tax defaulters
Loans to participators: s 455
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
One minute with... Tom Margesson
Modernising the taxation of distributions