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TAX POLICY ADMINISTRATION
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
Writing on behalf of The 100 Group’s Tax Committee, David Gordon calls for stable business taxes, simpler rules and wider access to advance tax certainty to help the UK compete for investment.
Company distributions: two consultations, fundamental changes ahead
Paul Rattew
John Endacott
John Endacott and Paul Rattew (PKF Francis Clark) examine proposed reforms to company distributions and the taxation of value extracted by private shareholders.
Incorporating an LLP: direct tax considerations
Joe Robinson
Harvey Innocent
Joe Robinson and Harvey Innocent (Macfarlanes) explain how LLP members may defer gains when transferring their interests to a company, while highlighting additional complications for corporate members and goodwill.
CGT equalisation and share plans: what should remain different?
Nigel Watson
Claire Withers
With speculation over the alignment of CGT and income tax rates,
Claire Withers and Nigel Watson (Burges Salmon) ask what that would mean
for employee equity and which policy choices it would leave unresolved.
The Orsted ‘tax nothing’
Andrew Page
Andrew Page OBE (formerly HMRC) argues that the denial of relief for
windfarm survey costs exposes a gap between the rules for capital allowances
and intangible assets.
Employment-related securities: the fallout from Vermilion
David Pett
David Pett (Temple Tax Chambers) writes that the FTT in CooperVision has
‘muddied the waters’ and made it more difficult to advise on whether shares
are employment-related securities.
Receivables finance: recent developments
Matthew Mortimer
Elmira Jazottes
Matthew Mortimer and Elmira Jazottes (Mayer Brown) assess the impact
of recent VAT decisions and changes to the UK tax net on the taxation of
receivables finance structures.
Tax and the City for October 2026
Zoe Andrews
Mike Lane
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments
including the latest GloBE package, Hunt on the limits of judicial correction, a
timely reminder of the significant contribution made by the financial services,
and the UTT implications of HMRC’s VAT guidance on fund management.
Knights and treaty interpretation
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) examines the Upper Tribunal’s ruling that the UK-Isle of Man treaty permits UK taxation of an offshore developer’s property profits, despite the lack of a UK permanent establishment.
HMRC powers and the taxpayer relationship: when is enough, enough?
Constantine Christofi
Craig Kirkham-Wilson
Chris Sanger
New HMRC measures risk cumulative constitutional and practical
effects that piecemeal consultation may fail to reveal, write Chris Sanger,
Constantine Christofi and Craig Kirkham-Wilson (EY).
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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
Effective consultation supports coherent and coordinated tax reform, says CIOT
Chancellor reportedly rejects alignment of CGT and income tax rates
CIOT seeks clarity on interest relief after capital withdrawals
HMRC launch online service for climate change levy returns
Consultation on plastic packaging tax
CASES
Read all
J Smith v HMRC
J Smith v HMRC
The Nigel Blackwell Family Trust and others v HMRC
Other cases that caught our eye: 16 October 2026
HMRC v British Airways plc
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
Victoria Oil & Gas plc v HMRC
Bolt: Supreme Court refuses permission to appeal
Loans to participators: s 455
AI and the unwinnable case
Modernising the taxation of distributions