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TAX POLICY
International review for May 2021
Tim Sarson
Recent developments that matter from around the globe, reported by
Tim Sarson (KPMG).
Cryptoassets: examining HMRC’s manual
Laura Mullarkey
Richard Sultman
Richard Sultman and Laura Mullarkey (Cleary Gottlieb Steen & Hamilton) consider HMRC’s new manual that sets out a more comprehensive and coordinated approach.
The Scottish elections: what now for tax?
Joanne Walker
Justine Riccomini
Justine Riccomini (ICAS) and Joanne Walker (LITRG and CIOT) consider
the detail of Scottish taxation policy for the next parliamentary term.
The Biden administration’s international tax proposals: will they fly?
Matthew D. Cutts
Linda Pfatteicher
Robert O'Hare
Jefferson VanderWolk
Jefferson VanderWolk, Matthew D Cutts, Linda Pfatteicher and Robert O'Hare (Squire
Patton Boggs) discuss the prospects for President Biden’s global tax plans.
Why constructive ambiguity is sometimes the best policy
Jeremy Mindell
Jeremy Mindell (Primondell) believes that judicial interpretation of existing
legislation is preferable to a wholesale codification of the law that would
become outdated and easy to manipulate.
Conflicts in the tax code: two case studies
Edward Milliner
A recent case and an old conundrum provide neat illustrations of the problems that arise when statutory provisions come into conflict, as Edward Milliner (Slaughter and May) reports.
Wellcome Trust and the reverse charge
Etienne Wong
There are always corners hidden in the world of VAT that bear illumination,
writes Etienne Wong (Old Square Tax Chambers).
Creating a tax system fit for the 21st century
Paul Aplin OBE
Former ICAEW president, Paul Aplin OBE, believes that this will need
stakeholder engagement, investment in technology and a willingness to
think outside the box.
Carbon pricing and the drive to net-zero
Jason Collins
Catherine Robins
Jason Collins and Catherine Robins (Pinsent Masons) discuss climate
change policy and how the government can take the lead in setting a roadmap
to help companies to make the long-term decisions that are required.
Tax changes from April 2021
Dan Nazarian
Natalie Backes
Michelle Robinson
Donna Huggard
This report sets out the key tax changes effective from April. It was prepared by Natalie Backes, Donna Huggard, Dan Nazarian and Michelle Robinson of Deloitte.
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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
Bolt: Supreme Court refuses permission to appeal
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
HMRC name 196 deliberate tax defaulters
Victoria Oil & Gas plc v HMRC
Loans to participators: s 455