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TAX POLICY ADMINISTRATION
HMRC v The Taxpayer: balancing the public and private
Hugh Gunson
Hugh Gunson (Charles Russell Speechlys) examines when it is possible to obtain privacy and/or anonymity orders in tax tribunal proceedings in light of a recent Upper Tribunal decision.
Planning for the merged R&D regime
Carrie Rutland
James Rolfe
Carrie Rutland and James Rolfe (BDO) highlight practical issues concerning
the introduction of the new scheme which takes effect from April.
HMRC’s assessment powers: key considerations
Matthew Greene
Guy Bud
HMRC’s assessment powers vary depending on the tax at issue but there are common themes, write Matthew Greene and Guy Bud (Stewarts).
The future of alternative dispute resolution in HMRC
Fiona McRobert
Fiona McRobert, Assistant Director of HMRC’s ADR Team, explains how the department is ‘looking to embed a resolution mindset’.
Incorporation relief and ESC D32: a myriad of uncertainty
Gordon W Buist
Gordon W Buist (EQ Accountants) explains how the publication of
Spotlight 63 on landlord tax planning schemes has exposed a fundamental
flaw with incorporation relief from CGT.
US limited liability corporations: updated HMRC guidance
Sebastian Prichard Jones
Andrew Crozier
HMRC’s updated guidance on the treatment of profits arising within, and
distributions from, US LLCs is unsatisfactory in a number of respects, write
Sebastian Prichard Jones and Andrew Crozier (Macfarlanes).
Private client review for January 2024
Edward Reed
Angus Richardson
PPR relief, transfer of assets abroad, information notices and the taxation of f
inder’s fees are among the topics in this month’s review by Edward Reed and
Angus Richardson (Macfarlanes).
UK holding companies: why they are still holding strong?
Artem Vasyutin
Sophie Hatton
As a territorial tax regime, the UK has a number of benefits, which have only increased over the last two decades, write Artem Vasyutin and
Sophie Hatton (
Deloitte).
The Scottish Budget 2024/25: widening the divergence
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) report on Scotland’s latest Budget, which introduces a new ‘advanced’ rate of income tax.
Tax in 2024 and beyond
Bill Dodwell
Increased digital reporting, the implementation of Pillar Two, potential further reforms to pensions tax... Bill Dodwell, former Tax Director of the Office of Tax Simplification, looks at what’s in store for tax in the year ahead.
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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 step up VAT scrutiny as large and medium sized-business investigations rise 31%
Government announces increase to Electricity Generator Levy
CIR returns
HMRC issue updated VAT road fuel scale charges
CCA scheme extended to new sectors and updated guidance issued
CASES
Read all
Orsted West of Duddon Sands (UK) Ltd (now named Orsted Schroders Greencoat WODS Holdco Ltd) and others v HMRC
Centrica Energy Storage Ltd v HMRC
Clearwater Hampers Ltd v HMRC
Other cases that caught our eye: 24 April 2026
CATS North Sea Ltd v HMRC
IN BRIEF
Read all
IHT and pensions
Mega Marshmallows and the meaning of ‘normally’
ATED: a reminder
UK short-term business visitors: the Appendix 4 report
Tax advisers: sanctionable conduct
MOST READ
Read all
Section 171A elections
HMRC loans to participators tool
Tax advisers: sanctionable conduct
Case watch
HMRC manual changes: 17 April 2026