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LITIGATION
Judicial review of exchange of information requests
Gary Barnett
Monique van Herksen
Monique van Herksen and Gary Barnett (Simmons & Simmons) examine
a recent decision of the CJEU that presents a setback for taxpayers in this
developing area of law.
Boulting: jurisdiction and the rule of law
Constantine Christofi
Robert Waterson
Adam Craggs
Adam Craggs, Robert Waterson and Constantine Christofi (RPC) examine the High Court decision that refused permission to bring a judicial review claim against HMRC.
AXA v Genworth: gross misunderstandings?
Helen Coward
Helen Coward (Charles Russell Speechlys) reviews a recent High Court case
on the meaning of a gross-up clause in a share purchase agreement.
Charman: old ERS law, new insights
Nigel Doran
Philip Swinburn
Nigel Doran and Philip Swinburn (Macfarlanes) examine the Upper Tribunal decision on the employment-related securities provisions of ITEPA 2003 Part 7.
Parry: pension transfers and omissions
Matthew Harrison
Matthew Harrison (Withers) examines the impact of a recent Supreme Court decision.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
Company residence
Jackie Wheaton
Jackie Wheaton (BDO) examines the case law in determining when a company is resident in the UK for tax purposes.
Tyrwhitt: when employees become partners
Dominic Stuttaford
Sofia Casselbrant
Dominic Stuttaford and Sofia Casselbrant-Multala (Norton Rose Fulbright)
review the NICs treatment of bonus payments by LLP to former employees
who subsequently become members.
Apple: the Commission fails to overcome its evidential burden
Tarlochan Lall
George Peretz KC
The General Court’s decision shows the difficulties the European Commission
faces in proving selective tax advantages that may constitute unlawful state
aid, write George Peretz QC and Tarlochan Lall (Monckton Chambers).
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51
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
NEWS
Read all
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
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
IHT replacement property relief restrictions
Consultation tracker