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LITIGATION
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).
Negative earnings: how wide is their scope?
Nigel Doran
The scope of negative earnings is almost certainly wider than has generally
been appreciated, writes Nigel Doran (Macfarlanes).
JJ Management Consulting: HMRC’s right to conduct informal investigations
Jessica Hocking
Kate Ison
A recent Court of Appeal decision reaffirms HMRC’s right to conduct enquiries on an ‘informal’ premise even where there is no statutory basis, write Kate Ison and Jessica Hocking (Bryan Cave Leighton Paisner).
Landlinx, VAT and call options: HMRC’s famous public disaster
Chris Nyland
The treatment of call options had been considered settled for over 40 years, but HMRC now wishes to reimagine it. Chris Nyland (Gowling WLG) analyses the merits of HMRC’s logic and its actions.
IR35: why (and when) mutuality of obligation matters
Derek Francis
Contrary to HMRC’s guidance and CEST tool, mutuality of obligation is pivotal to determining employment status in surprising ways. Derek Francis (Terra Firma Chambers) examines cases showing how.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC to restart direct recovery of tax debts
Tax agents legislation misses the target, says ICAEW
HMRC issue guidance on international employee earnings
Reserved investor funds: new technical note
Umbrella companies: new HMRC PAYE guidance
CASES
Read all
T Pawar v HMRC
MBP Europe Ltd v HMRC
Circleplane Ltd v HMRC
Other cases that caught our eye: 26 September 2025
The Prudential Assurance Company Ltd v HMRC
IN BRIEF
Read all
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
MOST READ
Read all
P Collingwood v HMRC
The hidden costs of a cap on lifetime gifting
The future of international tax reform
UK-Vietnam tax treaty updated
The Prudential Assurance Company Ltd v HMRC