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LITIGATION
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).
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).
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC confirm all SA109 taxpayers exempt from MTD until April 2027
CBAM emissions and verification draft regs: consultation
BPR and APR apportionment tool
GfC18: VAT place of supply in oil and gas sector
E-invoicing confusion highlighted by HMRC research
CASES
Read all
CATS North Sea Ltd v HMRC
Bilfinger Salamis UK Ltd v HMRC
Other cases that caught our eye: 17 April 2026
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
IN BRIEF
Read all
Tax advisers: sanctionable conduct
Section 171A elections
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
MOST READ
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J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
HMRC v Colchester Institute Corporation
Staggered roll-out for mandatory tax adviser registration
Consultation tracker