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TAX POLICY ADMINISTRATION
Capital allowances: a question of design?
Paul Farey
Paul Farey (AECOM) considers the impact of the Upper Tribunal’s ruling in
the
Gunfleet Sands
case.
The illusion of choice: the CIS in the DRC
Chris Nyland
Embedding the construction industry scheme into the VAT domestic reverse
charge wasn’t a wise move, writes Chris Nyland (Scammell & Nyland).
Autumn Statement 2023: a Budget in all but name?
Chris Sanger
Exactly what sort of an event was this, asks Chris Sanger (EY).
Tax and the City review for November 2023
Zoe Andrews
Mike Lane
Target Group
,
Vermilion
and changes to HMRC’s guidance on the double tax
treaty passport scheme are among the developments examined by Mike Lane
and Zoe Andrews (Slaughter and May).
M Group Holdings: time for a law change
Alistair Godwin
In light of the Upper Tribunal’s recent decision which took a restrictive view
of the substantial shareholding exemption rules, a change to the legislation is
now required, writes Alistair Godwin (EY).
Tax simplification: HMRC’s revised approach
Jonathan Athow
Jonathan Athow, HMRC’s director general of customer strategy and tax
design, explains why tax simplification matters to HMRC and what they are
doing to help deliver it.
Transfer pricing and intangibles: are all the issues priced in?
Alex Rigby
James Anderson
James Anderson and Alex Rigby (Skadden) examine HMRC’s package of
proposed transfer pricing reforms, and consider how they might assist with
existing uncertainty and double taxation disputes.
The stamp taxes on shares modernisation: modern enough?
Richard Sultman
Peter North
While awaiting the outcome of HMRC’s consultation on stamp tax
modernisation, Richard Sultman and Peter North (Cleary Gottlieb) consider
some missed opportunities and unresolved issues.
Blurred lines: occupation, profession or vocation?
Liesl Fichardt
Emily Au
Identifying an occupation is a cornerstone of the sale of occupational income rules. As those rules are increasingly invoked by HMRC, Liesl Fichardt and Emily Au (Quinn Emanuel) examine the guiding principles to identify an occupation, profession and vocation, and highlight the areas of obscurity.
Domicile disputes: actions speak louder than words
Hugh Gunson
Louise Paterson
With HMRC’s scrutiny of taxpayers’ domicile status showing no signs of abating, Hugh Gunson and Louise Paterson (Charles Russell Speechlys) examine key lessons from recent case law.
Go to page
of
601
EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for December
HMRC manual changes: 12 December 2025
Finance Bill 2026 published
HMRC revise position on VAT grouping and the Skandia judgment
HMRC explain TOMS changes
CASES
Read all
Cases of 2025
Places for People Homes Ltd v HMRC
Executor of P Goudman-Peachey v HMRC
HMRC v M Breen
Other cases that caught our eye: 5 December 2025
IN BRIEF
Read all
TSI Instruments and import VAT recovery
Voluntary returns and impossible penalties
Budget 2025 changes to the share exchanges and reorganisation rules
Fixing the FIG regime before extending it
Welsh Government consults on LTT and other tax changes
MOST READ
Read all
Budget 2025 changes to the share exchanges and reorganisation rules
The 2025 loan charge review and Government response: the final chapter?
TSI Instruments and import VAT recovery
Tax Journal's 2025 Budget coverage
Finance Bill 2026 published