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Tax risk
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TAX RISK
You can Reid all about it (because it’s not privileged)
Kyle Rainsford
Victoria Hine
Kyle Rainsford and Victoria Hine (Addleshaw Goddard) examine what is
believed to be the first case which has applied the iniquity principle in relation
to tax advice.
Carry on paying on account (or risk paying more)
Frankie Beetham
Ceinwen Rees
The newly reformed tax on carried interest will subject carried interest to the
payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland
& Ellis) set out some of the key practical considerations.
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.
Lessons in disguise: tax mistakes and rescission
Arthur Wong
Ben Elliott
The recent cases of
Bhaur
and
JTC
illustrate the opportunities and challenges for taxpayers who have misunderstood the tax consequences of a transaction, write Ben Elliott and Arthur Wong (Pump Court Tax Chambers).
Tax insurance: taxation of proceeds and gross-up
Laura Foley
Tom Cartwright
The taxation of insurance proceeds is relevant for sizing a policy limit.
Laura Foley and Tom Cartwright (Certa Insurance) consider various
practical scenarios and implications.
Tax risk insurance: a practical guide
Ben Jones
Jannine Nicholas
Helen Mackey
Ben Jones, Helen Mackey and Jannine Nicholas (Eversheds Sutherland) explain how to obtain and maximise the benefits of tax risk insurance.
Couldn’t careless? Reasonable care and the role of professional advisers
Constantine Christofi
Adam Craggs
Whilst taking professional advice will usually mean a taxpayer has taken
reasonable care, not taking advice does not necessarily mean a taxpayer has
been careless, write Adam Craggs and Constantine Christofi (RPC).
Tax risks and W&I-backed transactions: a good combination?
Lois Dale
Zita Dempsey
A buyer should not automatically assume a W&I-backed tax deed is appropriate for its transaction, write Zita Dempsey and Lois Dale (Pinsent Masons).
Umbrella companies
John Chaplin
Rob Woodward
John Chaplin and Rob Woodward (BDO) explain the main tax consequences associated with the use of umbrella company structures.
International issues: mitigating controversy
Don Morley
Yvonne Cypher
Basim Khattab
Don Morley, Yvonne Cypher and Basim Khattab (PwC) explain the importance of businesses retaining documentation of commercial decision making as HMRC increasingly focuses on areas of international tax risk.
Go to page
of
10
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 19 September 2025
Chancellor commits to business rates reform
CIOT warns of ‘unintended complexity’ in APR/BPR draft legislation
Professional bodies analyse draft Finance Bill legislation
Changing the timing of land remediation relief may prove beneficial, says CIOT
CASES
Read all
The Prudential Assurance Company Ltd v HMRC
P Collingwood v HMRC
K (oao Hotelbeds UK Ltd) v HMRC
Other cases that caught our eye: 19 September 2025
SC Arcomet Towercranes SRL
IN BRIEF
Read all
Supreme Court in Prudential Assurance
The hidden costs of a cap on lifetime gifting
SDLT and the funding of a purchase by a partner
Tribunal orders HMRC to disclose whether it used AI in R&D claims
Second home dilemma for SDLT
MOST READ
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Tribunal orders HMRC to disclose whether it used AI in R&D claims
Pre-Budget speculation fuels rumours of bank windfall tax and landlord NICs
EV charging added to advisory fuel rates
Budget 2025 set for 26 November
The hidden costs of a cap on lifetime gifting