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COMPLIANCE
AI in tax disputes: risks and routes of challenge
Liesl Fichardt
Emily Au
Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in
tax disputes and the implications for transparency, fairness and taxpayer
challenges.
So much ‘noise’: HMRC’s evolving approach to corporate compliance
Vicky Topps
Karmjit Mader
HMRC’s increasing focus on upstream compliance and a more data-led, riskbased
approach marks a clear shift away from the traditional enquiry cycle,
as Vicky Topps and Karmjit Mader (KPMG) explain.
HMRC’s Customer Compliance Group explained
Amit Puri
Amit Puri (Pure Tax Investigations) outlines the structure, resourcing and recent performance of HMRC’s Customer Compliance Group, including trends in compliance yield and investigation activity.
Mandatory agent registration: what we know so far
Jane Mellor
HMRC’s latest guidance still leaves key questions unanswered, writes Jane Mellor, Head of Professional Standards at the CIOT and ATT.
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Jack Gifford (EY) shares practical views on two of the most pressing Pillar Two issues for UK multinationals: the newly released Side-by-Side package and the fast approaching initial GIR filing deadline.
A new service for tax certainty on major projects
Finn Halton
Gregory Price
HMRC’s new service could provide a valuable focused engagement channel for major investments, write Gregory Price and Finn Halton (Macfarlanes).
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
FA 2025 review: The loans to participators regime no more (re)paying your way
Hugh Gunson
With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The loans to participators rules in...
Pillar Two compliance: the view from the 100 Group Tax Committee
Dominic Mathon
Writing on behalf of the 100 Group Tax Committee, Dominic Mathon reports views from the Committee's members on how much additional tax they expect to pay as a result of Pillar Two - and the associated compliance costs.
Digital platforms: reporting for duty
Max Schofield
New reporting requirements for platform operators come into force from 1 January 2024, explains Max Schofield (Devereux Chambers).
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Consultation tracker
One minute with… Jon Claypole