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TAX POLICY ADMINISTRATION
EOTs: defending the indefensible or challenging the undefinable
David Alcock
Ritchie Tout
David Alcock (Anthony Collins Solicitors) and Ritchie Tout (Azets) explain
why these structures are increasingly under the spotlight.
Why can’t we love HMRC like we love the NHS?
Jonathan Riley
Raising professional standards isn’t just an issue for advisers. Jonathan Riley (PKF Francis Clark) discusses the challenges facing HMRC.
Rebel without a causal link: HMRC’s position on proving carelessness
Sophie Rhind
Victoria Braid
Mainpay
should end any suggestion by HMRC that they can score a ‘knockout’ by identifying an area of carelessness, write Sophie Rhind and Victoria Braid (Macfarlanes).
Have we lost the ‘art’ in UK tax valuations?
Pavan Singh
Tax valuation methodologies have evolved. Pavan Singh (Eight Advisory)
considers whether the ‘art’ of valuations has been lost to too much ‘science’.
Hughes: a triumph which masks a forensic disaster
Jonathan Fisher KC
Insights into HMRC’s practices in the investigation of an allegedly complex
tax fraud described in the court’s judgment makes for compelling reading, as
Jonathan Fisher KC (Red Lion Chambers) explains.
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L Korb
Andrew Solomon
Donald L Korb and Andrew Solomon (Sullivan & Cromwell) assess US views on the two-pillar proposals and the domestic tax policies of the two candidates for US President.
Get Onbord and Tills Plus: some encouragement for taxpayers in R&D disputes
Thomas Chacko
In two recent cases, the tribunal approached the question of what was
qualifying research in a way that supports taxpayers’ claims, if the right
evidence is presented, writes Thomas Chacko (Pump Court Tax Chambers).
Tax and the City review for September 2024
Mike Lane
Zoe Andrews
In this month’s review, Mike Lane and Zoe Andrews (Slaughter and May)
examine recent case law and draft legislation, and they look ahead to how
financial services will be taxed under the Labour government.
The path ahead for MTD: review or reflect?
Paul Aplin OBE
The new government should look at how MTD fits into plans for digitalisation of UK tax administration more generally and at the wider opportunities technology presents for taxpayers and HMRC, writes Paul Aplin OBE.
Estoppel in a tax context
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) explain how
estoppel has recently been used in tax cases by HMRC and also by taxpayers.
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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
HMRC v GCH Corporation Ltd and others
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
IHT replacement property relief restrictions
Consultation tracker