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TAX RISK
Tax Update 2026
A report by Lexis®+UK Tax
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
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).
Go to page
of
11
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
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
NEWS
Read all
Welsh tax Bill proposes repayment powers and LTT changes
Voluntary payrolling extended to accommodation and loans
Clarification sought on IHT exemption for charitable trusts
‘No separate VAT rules for cryptoassets’, HMRC say
CBAM: draft default emissions values published
CASES
Read all
ScottishPower (SCPL) Ltd and others v HMRC
T Bunting v HMRC
Brants Bridge Ltd and another v HMRC
Other cases that caught our eye: 23 October 2026
J Smith 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
The Nigel Blackwell Family Trust and others v HMRC
Chancellor reportedly rejects alignment of CGT and income tax rates
Incorporating an LLP: direct tax considerations
One minute with... Helen Miller
J Smith v HMRC