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TAX POLICY
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
Alan Rafferty
Ollie Winters
Jade Du Berry
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
Daria Nikitina
Simon Down
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.
International review for May 2026
Tim Sarson
Tim Sarson (KPMG) reviews fresh OECD Pillar Two guidance, the CJEU’s latest VAT and Transfer Pricing decision, growing interest in Digital Services Taxes and Canada’s delayed implementation of the Under-Taxed Profits Rule.
Comparing chancellors
Jeremy Mindell
Jeremy Mindell (Primondell) puts the current chancellor in historical context,
showing how past economic inheritances have shaped tax policy.
In conversation with... Paul Johnson
Paul Johnson
Anthony Inglese
Paul Johnson, former Director of the Institute for Fiscal Studies, talks to
Anthony Inglese CB about his career in economics and his views on UK
fiscal policy.
Mining for information: preparing for CARF
Yousuf Chughtai
Jack Prytherch
CARF may be just the beginning of a new age of tax enforcement and
scrutiny for the crypto industry, write Yousuf Chughtai and Jack Prytherch
(Osborne Clarke).
Legislation day 2025: R&D relief for Northern Ireland businesses
Jenny Tragner
The rushed implementation of ERIS continues to demonstrate why legislation should be properly consulted on before implementation.
Legislation day 2025: The APR and BPR reforms: sobering reading
Stuart Maggs
The Government might have consulted but it hasn’t listened.
Giving advice in uncertain times
Jeremy Mindell
Ongoing speculation over tax changes presents significant challenges for
delivering reliable advice, writes Jeremy Mindell (Primondell).
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EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
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
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
Consultation tracker
Management rollovers and share-for-share exchange relief
Sintra, Hall and the reshaping of HMRC’s burden of proof
The UK’s tax certainty problem
Information notices