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LITIGATION
A tale of two companies in two cities: the CJEU’s ruling on fixed establishment in Berlin Chemie
Karen Killington
Karen Killington (KPMG) considers the impact of a recent case where the CJEU held that a subsidiary was not a fixed establishment.
NCL Investments: an 11-0 taxpayer victory
Angela Savin
Michael Brady
Angela Savin and Michael Brady (KPMG Law) review the impact of a recent
Supreme Court ruling.
VolkerRail: applying retained EU case law in pre-Brexit years
Richard Doran
Davinder Sahota
A decision of the Upper Tribunal illustrates the difficulties of applying CJEU case law for disputes over pre-Brexit breaches of EU law, write Richard Doran and Davinder Sahota (EY).
Contentious tax quarterly
Lauren Redhead
Jason Collins
Your quarterly review of developments in the contentious tax world, by
Jason Collins and Lauren Redhead (DLA Piper).
Capital allowances: what is plant?
Paul Farey
Paul Farey (AECOM) examines two recent decisions that raise some unique considerations and add to the discussion as to what can qualify for plant and machinery allowances.
Urenco: plant and machinery allowances
Will Scott
Susie Brain
Will Scott and Susie Brain (Norton Rose Fulbright) examine an Upper Tribunal decision on the availability of capital allowances in the context of increasingly complex, technical assets used in the power generation industry.
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Allam: a case full of interest
Lynnette Bober
Lynnette Bober (Gateley Legal) takes a closer look at a case involving
several diverse issues, not least the difficulties in overturning findings of fact
by the FTT.
Report: Giving evidence from overseas
A Tolley report examines a recent decision of the immigration chamber of the
Upper Tribunal, which has implications for tax hearings.
Tax disputes in 2021: beware the clever procedural skirmish
Lauren Redhead
Jason Collins
Beware the clever procedural skirmish, warn Jason Collins and Lauren Redhead (DLA Piper).
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
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
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
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