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LITIGATION
Salaried members rules: the position for LLPs after BlueCrest
Ian Zeider
Emily Clark
Emily Clark and Ian Zeider (Travers Smith) revisit the Upper Tribunal’s salaried members judgment in
BlueCrest
, focusing on what it means for LLPs. Is there now more scope to claim ‘significant influence’, but perhaps less certainty of being on the right side of the line?
Carelessness and the requirement of causation
Ben Blades
Recent cases have diverged on the question of whether HMRC must establish that carelessness caused a loss of tax, writes Ben Blades (Gray’s Inn Tax Chambers).
Domicile disputes: actions speak louder than words
Hugh Gunson
Louise Paterson
With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
HMRC’s litigation and settlement strategy: an overview
Karmjit Mader
Annis Lampard
Annis Lampard and Karmjit Mader (Deloitte) provide a back to basics guide to HMRC’s framework for resolving civil tax disputes.
Conduct of proceedings in the Upper Tribunal: new guidance
Kelly Stricklin-Coutinho
New guidance has been issued on the conduct of proceedings in the Upper Tribunal. Kelly Stricklin-Coutinho (39 Essex Chambers) examines what’s changed.
You’re barred: failure to disclose in the FTT
Sophie Rhind
Victoria Braid
Sophie Rhind and Victoria Braid (Macfarlanes) examine a recent case in which the tribunal takes a tough approach to HMRC’s failure to comply with an unless order.
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
Nuel Oji
Stuart Walsh
Stuart Walsh and Nuel Oji (DLA Piper) examine lessons from a recent High Court judgment.
Contentious tax: 2023 mid-year review
Lauren Redhead
Emily Burke
Clara Boyd
Clara Boyd, Lauren Redhead and Emily Burke (DLA Piper) review the changing contentious tax landscape, including the courts continuing efforts on improving procedural certainty.
What happens at a tribunal hearing?
Anne Redston
Who sits where? What should you ask witnesses? When should you interrupt? Barrister Anne Redston provides a beginner’s guide to representing taxpayers at the tribunal.
SSE Generation: when is a tunnel a tunnel?
Will Scott
It all depends on the context... Will Scott (Norton Rose Fulbright) assesses the impact of a Supreme Court decision on the availability of capital allowances for increasingly novel technologies.
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 9 January 2026
Agreement reached on Pillar Two ‘side-by-side’ package
Late change lifts BPR/APR cap
New guidelines on imported hybrid mismatch rules
VAT treatment of supplies of temporary medical staff
CASES
Read all
HMRC v Hotel La Tour Ltd
County Insurance Services Ltd v HMRC
The Tower One St George Wharf Ltd v HMRC
R Sehgal v HMRC
Other cases that caught our eye: 9 January 2026
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Agreement reached on Pillar Two ‘side-by-side’ package
The Tower One St George Wharf Ltd v HMRC
Share reorganisations: new anti-avoidance rules explained
R Sehgal v HMRC
HMRC manual changes: 9 January 2026