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TAX POLICY ADMINISTRATION
The curious case of Uncertain Tax Treatments
Yousuf Chughtai
Jack Prytherch
HMRC’s newly published materials raise important questions about
how taxpayers are engaging with the UTT regime in practice, writes
Yousuf Chughtai and Jack Prytherch (Osborne Clarke).
The ICTS: a new chapter in transfer pricing compliance
Andrew Stewart
Amy Clarke
The International Controlled Transaction Schedule is expected to be
introduced in the UK in the foreseeable future. Andrew Stewart and
Amy Clarke (BDO) explain how to prepare.
AI in a new tax (3.0) world
Conrad Young
Tax technology adviser Conrad Young considers AI's rapidly increasing role for tax authorities and tax market participants.
Tax and the City review for September 2025
Mike Lane
Zoe Andrews
The tribunal decision in
Currys
on the degrouping charge and L-day material relevant to financial institutions are among the developments in this month's review by Mike Lane and Zoe Andrews (Slaughter and May).
Secondary legislation: the importance of statutory instruments
Alan Evans CB
Alan Evans CB, HMRC’s General Counsel and Director General of the
department’s Legal Group, discusses an often overlooked but crucial part to
the running of the tax system.
The Temporary Repatriation Facility opportunity
Alice Pearson
The Temporary Repatriation Facility could create significant tax savings
for some. Alice Pearson (Mercer & Hole) highlights some practical
considerations and areas of complexity.
You can Reid all about it (because it’s not privileged)
Victoria Hine
Kyle Rainsford
Kyle Rainsford and Victoria Hine (Addleshaw Goddard) examine what is
believed to be the first case which has applied the iniquity principle in relation
to tax advice.
Transformation Roadmap
Paul Aplin OBE
HMRC’s new roadmap heralds a step-change in the department’s digital
ambition, writes Paul Aplin OBE.
OBBBA: a new era in Republican tax legislation
Aharon Friedman
Andrew Solomon
Andrew Solomon and Aharon Friedman (Sullivan & Cromwell) review the
One Big Beautiful Bill as a whole and look ahead to what’s next.
Legislation Day: draft Finance Bill 2026
A detailed report by Lexis®+ UK Tax with additional practitioner insight.
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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