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LITIGATION
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
Kate Ison
Jessica Hocking
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.
Informal enquiries and voluntary disclosures
Emily Clark
Sometimes you can be too relaxed.
Sippchoice: the meaning of ‘contributions paid’
Matthew Harrison
Matthew Harrison (Withers) examines the Upper Tribunal decision concerning the registered pension scheme regime.
Accelerated payment notices and penalties
David Whiscombe
The unsatisfactory truth.
NCL Investments: upholding the primacy of accounts
Dominic Stuttaford
Susie Brain
Dominic Stuttaford and Susie Brain (Norton Rose Fulbright) examine the Court of Appeal decision.
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51
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