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Tax policy & administration
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TAX POLICY ADMINISTRATION
From Swiss Re to Lloyd’s: lessons in tax leadership
Michael Ludlow
It’s not just about technical brilliance. Michael Ludlow (Lloyd’s) sets out his
leadership framework for in-house tax teams.
Close encounters with close companies (part 2): common issues in practice
Hannah Manning
Ross McGregor
There is a myriad of anti-avoidance legislation which must be carefully
considered throughout the lifecycle of a close company. Hannah Manning
and Ross McGregor (Travers Smith) explain how to avoid some of the
common pitfalls.
International review for October 2025
Tim Sarson
This month’s update by Tim Sarson (KPMG) has a distinctly European
flavour, and illustrates how politics – and not always domestic politics –
influences tax policy.
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
Fraud: the next ‘failure to prevent’ frontier
Nicholas Gardner
Ruby Hamid
The new fraud offence is a notable expansion of the failure to prevent (FTP)
model creating corporate criminal liability. Ruby Hamid and Nicholas
Gardner (Ashurst) examine actions for companies, and compare the rules
with the existing FTP offences for bribery and tax evasion.
OBBBA: one big beautiful guide for non-US tax professionals
Mark Saunderson
Paul McColgan
Jason Groves
Jason Groves, Mark Saunderson and Paul McColgan (Deloitte) set out
some recommendations for UK professionals advising businesses with large
US operations.
GfC 13 and the filing position: nothing to see here?
Angela Savin
Andrew James
Angela Savin and Andrew James (KPMG Law) explain how HMRC are aiming to reduce the ‘legal interpretation’ tax gap by urging taxpayers to disclose ‘novel or uncertain positions’.
Across the pond: comparing US and UK M&A tax protections
Simon Skinner
Richard Liu
With the increasing prevalence of US buyers of UK businesses, and consequently more ‘US-style’ deals than ever, Simon Skinner and Richard Liu (Latham & Watkins) de-mystify what this means and explain the key differences in US market practice for M&A tax protections.
How to interpret double tax treaties
Kyle Rainsford
Following a recent flurry of cases, Kyle Rainsford (Addleshaw Goddard)
revisits the basic principles of interpreting tax treaties in the UK.
The future of international tax reform
Philip Baker KC
The prognosis for international tax reform does not look good, writes
Philip Baker KC (Field Court Tax Chambers).
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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 confirm all SA109 taxpayers exempt from MTD until April 2027
CBAM emissions and verification draft regs: consultation
BPR and APR apportionment tool
GfC18: VAT place of supply in oil and gas sector
E-invoicing confusion highlighted by HMRC research
CASES
Read all
CATS North Sea Ltd v HMRC
Bilfinger Salamis UK Ltd v HMRC
Other cases that caught our eye: 17 April 2026
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
IN BRIEF
Read all
Tax advisers: sanctionable conduct
Section 171A elections
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
MOST READ
Read all
Consultation on proposed UK corporate re-domiciliation regime
R (oao Rokos) v HMRC
Staggered roll-out for mandatory tax adviser registration
HMRC v Colchester Institute Corporation
Case watch