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TAX POLICY ADMINISTRATION
OBBBA: a new era in Republican tax legislation
Aharon Friedman
Andrew Solomon
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the
One Big Beautiful Bill as a whole and look ahead to what’s next.
Legislation Day: draft Finance Bill 2026
A detailed report by Lexis®+ UK Tax with additional practitioner insight.
Carried interest: the L-day changes
Bezhan Salehy
Damien Crossley
The draft Finance Bill provisions seek to address some of the issues for credit
funds, write Bezhan Salehy and Damien Crossley (Macfarlanes).
Legislation day 2025: Requirement for advisers to register with HMRC
David Whiscombe
Worse than useless?
Close encounters with close companies (part 1): definitions and concepts
Hannah Manning
Ross McGregor
In the first of two articles examining the close companies rules, Hannah
Manning and Ross McGregor (Travers Smith) explain why it should not be
assumed that a company is not close without looking carefully at the relevant
legislation.
Carry on paying on account (or risk paying more)
Ceinwen Rees
Frankie Beetham
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.
BGC Services: lacking determination
Matthew Greene
Guy Bud
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision
which stresses the need for accountability and transparency from HMRC
when issuing determinations.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
It’s Consultation, Jim – but not as we know it...
Chris Sanger
At first glance, the Government’s revised approach to tax policy making retains
much of the existing framework. There is, however, a significant change on the
commitment to consultation, writes Chris Sanger (EY).
The trials and tribulations of interest withholding tax
Bezhan Salehy
Elvira Colomer Fatjo
Rebecca Rose
Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes)
take a practical look at UK interest withholding tax, highlighting common
compliance pitfalls, HMRC’s approach and emerging complexities.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime
Consultation tracker
IHT replacement property relief restrictions