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TAX POLICY ADMINISTRATION
Uncertain tax treatments consultation: extending uncertainty?
Yousuf Chughtai
Jack Prytherch
Jack Prytherch and Yousuf Chughtai (Osborne Clarke) assess HMRC’s plans
to widen the UTT regime and the practical implications for taxpayers.
Deferred remuneration: HMRC update their guidance on cross-border tax and NICs
Lika Jatoeva
Nigel Doran
Nigel Doran and Lika Jatoeva (Macfarlanes) review HMRC’s updated
guidance on deferred remuneration for internationally mobile employees and
consider the resulting risks of double taxation and NICs mismatches.
AI in tax disputes: risks and routes of challenge
Liesl Fichardt
Emily Au
Liesl Fichardt and Emily Au (Quinn Emanuel) consider the use of AI in
tax disputes and the implications for transparency, fairness and taxpayer
challenges.
UK CBAM: key questions for importers of high-carbon goods
James Camidge
Abhay Srivastava
Abhay Srivastava and James Camidge (Weightmans) explain what the UK
CBAM is and how to prepare for the compliance challenge ahead.
Too close for comfort? HMRC consult on a new reporting obligation for close companies
Rob Sharpe
Thomas Peet
Rob Sharpe and Thomas Peet (Cleary Gottlieb) examine HMRC’s proposals
to require close companies to report all transactions with participators,
assessing the likely compliance burden and unintended impact beyond small
businesses, particularly for private capital structures.
MTD regulations: legislation at the eleventh hour
Emma Rawson OBE
Emma Rawson (ATT) reviews the MTD for Income Tax regulations,
highlighting late legislative changes, complex entry and exit rules, quarterly
reporting mechanics, and the wide-ranging exemption regime.
Finance Act 2026
Ros Martin
Consultant Ros Martin provides an overview of this year’s Finance Act, including reforms to income tax and inheritance tax, the recast carried interest regime, changes to capital allowances and venture capital schemes, and expanded compliance and anti-avoidance provisions.
Penalty suspension
Abigail McGregor
Jake Landman
Jake Landman and Abigail McGregor (Pinsent Masons) revisit the
discretionary regime allowing HMRC to suspend penalties for careless
inaccuracies, in light of recent Upper Tribunal guidance.
What is a Scottish taxpayer and what happens when they move during a tax year?
Chris Campbell
As Scotland diverges from UK tax rates, Chris Campbell (ATT) explains the importance of correctly identifying Scottish taxpayers.
PE: don’t believe the hype
Nick Thornton
Is the UK’s domestic Permanent Establishment definition reform fair,
simple and supportive of growth, or is it, in reality, yet further complexity,
asks Nick Thornton (Fried Frank).
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EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
Tax Journal thanks its July 2026 authors
GAAR Advisory Panel issues Opinions on IHT planning arrangements
CIOT and ATT suggest priorities for new Financial Secretary
Pillar Two top-up taxes returns: deadline reminder
ATT cautions against ITSA ‘timely payment’ reforms
CASES
Read all
Ten cases shaping tax practice in 2026
New cases this week: 31 July 2026
M Elborne and others v HMRC
E Kwai v HMRC
P Reed v HMRC
IN BRIEF
Read all
Funding the business
HMRC’s annual report for 2025/26
The new duty to correct tax return errors
The VAT treatment of prize draws
Directors’ liability: tax schemes
MOST READ
Read all
The VAT treatment of prize draws
The new duty to correct tax return errors
Requirements for forthcoming pensions IHT changes
Loan charge settlement scheme: regulations and guidance published
One minute with... Tim Gummer