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HMRC powers
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HMRC powers
HMRC POWERS
HMRC’s revised R&D guidance: the end of a long and winding road?
James Dudbridge
HMRC’s updated guidance marks the end of a long and winding road for
R&D claimants and their advisers, writes James Dudbridge (ForrestBrown).
20 years of HMRC
Heather Self
Political pressure has resulted in HMRC adopting a slow and cautious decision-making process that remains to this day, writes Heather Self (Blick Rothenberg).
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.
Yorkshire Agricultural Society, consistent interpretation and the continued relevance of EU law
Edd Thompson
Edd Thompson (Forvis Mazars) explores the Upper Tribunal’s approach to
the principle of ‘consistent interpretation’ on the VAT charitable fundraising
exemption and considers its potential relevance in the post-Brexit era.
Disputes over LPP with third parties and HMRC: lessons from Castlet Holdings
Tristan Thornton
Joseph Howard
A recent FTT decision has exposed the inadequacies in how the rules deal with third party notices, write Joseph Howard and Tristan Thornton (Chancery Court Tax Chambers).
Tax and the City review for February 2025
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) examine recent tax
developments that matter, including the ruling in ScottishPower and HMRC’s
draft guidance on the multinational top-up tax and domestic top-up tax.
Map making
Paul Aplin OBE
We are promised a Digital Transformation Roadmap setting out how HMRC will be transformed into a digital-first organisation. Paul Aplin OBE hopes it will herald a more collaborative approach from the department.
Tax and the City review for January 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
covers the decisions in Refinitiv, Syngenta and Cobalt and HMRC’s updated
guidance on share exchanges.
HMRC’s defeats on subsidised and contracted out R&D
Benjamin Craig
Benjamin Craig (Ayming) examines the impact of two recent FTT decisions.
Corporate view: goodbye to 2024 – the year of two halves
Eloise Walker
It looks like any tax motivation is becoming fair game, writes Eloise Walker (Pinsent Masons).
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107
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
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
NEWS
Read all
Effective consultation supports coherent and coordinated tax reform, says CIOT
Chancellor reportedly rejects alignment of CGT and income tax rates
CIOT seeks clarity on interest relief after capital withdrawals
HMRC launch online service for climate change levy returns
Consultation on plastic packaging tax
CASES
Read all
J Smith v HMRC
J Smith v HMRC
The Nigel Blackwell Family Trust and others v HMRC
Other cases that caught our eye: 16 October 2026
HMRC v British Airways plc
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
Victoria Oil & Gas plc v HMRC
Bolt: Supreme Court refuses permission to appeal
Loans to participators: s 455
AI and the unwinnable case
Modernising the taxation of distributions