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COMPLIANCE
Uncertain tax treatment: highlights from HMRC’s final guidance
Kate Alexander
Nick Evans
Kate Alexander and Nick Evans (Baker McKenzie) review the newly published
Uncertain Tax Treatments by Large Businesses Manual.
The plastic packaging tax: how it works
Ugo Onwumelu
Charlotte Sallabank
Charlotte Sallabank and Ugo Onwumelu (Katten Muchin Rosenman) explain key features of the new tax and how it will apply to businesses.
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Does FATCA breach data protection? Jenny goes to court
Adam Rose
Filippo Noseda
Filippo Noseda and A
dam Rose (
Mishcon de Reya) discuss
the data protection repercussions of a system of automatic exchange of information in light of recent court decisions in the US and UK.
Consultation on the UK’s new mandatory disclosure rules
Veronica McMahon
Some of the definitions may have changed from DAC 6 to UK MDR, but the
concepts are broadly the same, writes Veronica McMahon (Osborne Clarke).
When is a defective HMRC notice invalid?
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.
Contentious tax quarterly
Constantine Christofi
Robert Waterson
Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Kate Alexander
Nick Evans
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
Jersey’s economic substance for partnerships rules
Rupert Lee
New legislation brings certain partnerships within the scope of Jersey’s economic substance regime. Rupert Lee (Deloitte Jersey) reports.
International issues: mitigating controversy
Don Morley
Yvonne Cypher
Basim Khattab
Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.
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173
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