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TAX POLICY ADMINISTRATION
The Big, Beautiful Bill: one House down, one House to go
Andrew Solomon
As the Senate prepares to take up President Trump’s sweeping tax and spending
package, Andrew Solomon (Sullivan & Cromwell) considers its key provisions
and what happens next.
Future focus: the potential reform of behavioural penalties
Thomas Wilkinson
Kate Garcia
Kate Garcia and Thomas Wilkinson (Shoosmiths) review the consultation on
the potential redesign or reform of penalties imposed for inaccuracies in tax
returns and failures to notify.
The Government amendments to domestic Permanent Establishment rules
Lorenza De Domenico
James Anderson
UK reforms to the permanent establishment rules and the Investment
Manager Exemption could reshape the tax treatment for non-resident
funds and UK investment managers, write James Anderson and Lorenza
De Domenico (Skadden).
Taxing rubbish: proposed overhaul of the landfill tax regime
Anastasia Nourescu
David Pickstone
David Pickstone and Anastasia Nourescu (Stewarts) consider the
Government’s proposed reform of the landfill tax regime and its impact
on industry.
Tribunal support for ADR: stick or carrot?
Peter Nias
Ben Elliott
Peter Nias and Ben Elliott (Pump Court Tax Chambers) consider a recent
practice statement and other measures supporting the greater use of ADR.
Improving HMRC’s approach to dispute resolution
Liam McKay
Adam Craggs
Adam Craggs and Liam McKay (RPC) examine the current consultation
which could help influence HMRC’s future approach to dispute resolution.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
Lifecycle of a transaction: Tax protections and W&I
Elizabeth Emerson
Matt Davies
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
Sarah Bond
Benjamin Crompton
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.
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612
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