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TAX POLICY ADMINISTRATION
Too close for comfort? HMRC consult on a new reporting obligation for close companies
Rob Sharpe
Thomas Peet
Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals
to require close companies to report all transactions with participators,
assessing the likely compliance burden and unintended impact beyond small
businesses, particularly for private capital structures.
MTD regulations: legislation at the eleventh hour
Emma Rawson
Emma Rawson (ATT) reviews the MTD for Income Tax regulations,
highlighting late legislative changes, complex entry and exit rules, quarterly
reporting mechanics, and the wide-ranging exemption regime.
Finance Act 2026
Ros Martin
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Penalty suspension
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
What is a Scottish taxpayer and what happens when they move during a tax year?
Chris Campbell
As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers.
PE: don’t believe the hype
Nick Thornton
Is the UK’s domestic Permanent Establishment definition reform fair,
simple and supportive of growth, or is it, in reality, yet further complexity,
asks Nick Thornton (Fried Frank).
Capital by name, income in nature: the Upper Tribunal’s decision in BCG
Henry Bennett-Gough
Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in
Boston Consulting Group
and its implications for mixed member LLP structures.
How AI can help democratise tax administration
Stephen Daly
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
HMRC’s Digital Disclosure Service: insights from practice
Tom O’Reilly
Jan Kolasa
Ben Webster
Ben Webster, Tom O’Reilly and Jan Kolasa (Fieldfisher) assess the strengths and weaknesses of the Digital Disclosure Service.
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Nick Thornton (Fried Frank) explains why clearing the entry conditions of the QAHC regime is only the start, and how accounting treatment, CIR and funding design can derail intended outcomes.
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EDITOR'S PICK
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
HMRC confirm all SA109 taxpayers exempt from MTD until April 2027
CBAM emissions and verification draft regs: consultation
BPR and APR apportionment tool
GfC18: VAT place of supply in oil and gas sector
E-invoicing confusion highlighted by HMRC research
CASES
Read all
CATS North Sea Ltd v HMRC
Bilfinger Salamis UK Ltd v HMRC
Other cases that caught our eye: 17 April 2026
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
IN BRIEF
Read all
Tax advisers: sanctionable conduct
Section 171A elections
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
MOST READ
Read all
Consultation on proposed UK corporate re-domiciliation regime
R (oao Rokos) v HMRC
Staggered roll-out for mandatory tax adviser registration
HMRC v Colchester Institute Corporation
Case watch