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IPT
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BEPS
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OMBs
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TAX POLICY ADMINISTRATION
Lifecycle of a transaction: Tax protections and W&I
Matt Davies
Elizabeth Emerson
Matt Davies and Elizabeth Emerson (DLA Piper) consider core tax
protections in share purchase agreements, and how they are impacted by tax
warranty and indemnity insurance.
Certainty in uncertain times
Erica Rees
Jenny Doak
Jenny Doak and Erica Rees (Weil, Gotshal & Manges) consider some of the
practical considerations surrounding the proposed process for providing
advance tax certainty for major projects.
TP, DPT and UTPP: twists, turns and transformations
Benjamin Crompton
Sarah Bond
Sarah Bond and Benjamin Crompton (Freshfields) examine the draft
legislation that amends certain aspects of the rules on transfer pricing and the
diverted profits tax.
Code of Practice 9 and discovery assessments
Michael Paulin
Michael Paulin (1 Crown Office Row) considers the impact of HMRC’s
broader view of tax fraud in its updated COP 9.
Time is money: how to mitigate late payment interest in tax disputes
Jack Prytherch
Jack Prytherch (Osborne Clarke) sets out the practical steps that taxpayers
can take to minimise delays in their disputes with HMRC and so mitigate any
additional interest charged.
Challenging the NICs Bill
Baroness Neville-Rolfe DBE CMG
The Shadow Treasury Minister in the House of Lords, Baroness Neville-
Rolfe DBE CMG, explains why and how the Opposition challenged the
Government’s NIC changes in the House of Lords.
The Reserved Investor Fund: a practitioner guide
Paul Shaw
Paul Shaw (Gowling WLG) provides a practical guide to the new regime.
Losses and major changes in the trade or business
John Angood
James Hewitt
John Angood and James Hewitt (BDO) provide a back to basics guide.
Whistleblowing
David Whiscombe
The Government’s plan to launch a new tax whistleblower scheme raises a
number of questions – and it’s not clear how many have been fully thought
through, writes David Whiscombe.
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) examines recent Government
proposals which, he says, leave little doubt that tax avoidance, like tax evasion,
is to be regarded as a criminal activity.
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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 loans to participators tool
Finance Act 2026