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TAX POLICY
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
Anthony Inglese
Paul Johnson
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
Jack Prytherch
Yousuf Chughtai
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).
OBBBA: permanent tax cuts and international adjustments
Andrew Solomon
Aharon Friedman
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) report on an
action-packed seven days in Washington.
Beard: dividends of a capital nature
Ashley Greenbank
Ashley Greenbank (Devereux Chambers) explains why form matters.
Tax insurance: underwriting and policy insights
Laura Foley
Tom Cartwright
Laura Foley and Tom Cartwright (Certa Insurance Partners) share insights
on the insurer’s perspective when underwriting tax risks, and the impact on
policy structure.
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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
Re Fulmar Contracting Ltd (In Liquidation) and others v M Williams and another
Loans to participators: s 455
Modernising the taxation of distributions
One minute with... Tom Margesson