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TAX POLICY
Using opinions of the GAAR Panel
Gary Richards
Gary Richards, Chair of the GAAR Advisory Panel, explains how the Panel makes its assessments and what advisers can learn from its published opinions.
OECD consultation on intra-group services: incremental change, persistent uncertainty
Robin Saunders
Phil Roper
Phil Roper and Robin Saunders (KPMG) assess the OECD’s proposed revisions to its Transfer Pricing Guidelines.
Legislation Day: draft Finance Bill 2027
A detailed report by Lexis+® UK Tax, with additional practitioner insight.
Welcome to the Hotel United Kingdom: the UK’s proposed re-domiciliation regime
Oliver Walker
Ellie Marques
Check in, but can you check out? Oliver Walker and Ellie Marques (Weil, Gotshal & Manges) explain why companies considering moving to the UK need to think carefully about the UK tax ramifications.
Contentious tax quarterly: Summer 2026
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) review recent procedural decisions on strike out, costs for HMRC’s pre-appeal conduct and disclosure, drawing out the practical risks for tax litigants.
Tax Update day: a flexible friend?
Chris Sanger
A useful release valve or a source of consultation overload? Chris Sanger (EY) examines how Tax Update days have become part of the UK tax policy cycle.
Mandatory tax adviser registration: clearer, but not clear enough
Emma Rawson OBE
Emma Rawson OBE (ATT) examines what can be learnt from HMRC’s new
Mandatory Tax Adviser Registration Manual.
CGT: what principles should guide reform?
David Martin
With capital gains tax once again under scrutiny, former practitioner
David Martin considers the principles that should underpin reform, from lower
rates and rollover relief to the relationship between CGT and income tax.
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Jade Du Berry
Alan Rafferty
Ollie Winters
The High Court has confirmed that HMRC do not have a veto over
restructuring plans. Alan Rafferty, Jade Du Berry and Ollie Winters (Milbank)
examine the implications of Waldorf, including HMRC’s constitutional
arguments, the treatment of tax losses and the evolving approach to cross-class
cram downs.
Steering EV tax strategy in the right direction
Simon Down
Daria Nikitina
Benefit in kind rates remain attractive for electric vehicles, but are only part of the picture. Simon Down and Daria Nikitina (Deloitte) explain why employers should adopt a total cost of operation approach to fleet strategy.
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202
EDITOR'S PICK
The Orsted ‘tax nothing’
Andrew Page
1 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
2 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
3 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
4 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
5 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
6 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
7 /7
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
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
NEWS
Read all
Conservatives pledge IHT exemption for family homes
Government accepts PAC recommendations on large business tax compliance
No breaches found under banks’ tax code
Distributions reform could hinder business transactions, CIOT warns
Bolt: Supreme Court refuses permission to appeal
CASES
Read all
HMRC v British Airways plc
Victoria Oil & Gas plc v HMRC
S Keswick and others v HMRC
Other cases that caught our eye: 9 October 2026
Jumpman Gaming Ltd v HMRC
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
HMRC name 196 deliberate tax defaulters
Loans to participators: s 455
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
One minute with... Tom Margesson
Modernising the taxation of distributions