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TAX POLICY ADMINISTRATION
Initiative and the tax tribunal: a higher calling?
Bridget Winters
Calum Young
In an adversarial system, when can the tribunal take the initiative and
reach decisions on arguments not made by counsel? Bridget Winters and
Calum Young (Taylor Wessing) investigate.
Suboptimal access: HMRC and data requests
Robert Waterson
Lucy Collins
Robert Waterson and Lucy Collins (Eversheds Sutherland) examine a recent
High Court ruling that could encourage individuals to challenge HMRC if
they feel their personal data rights are being infringed.
RBC: from the island of literal interpretation to the continental shelf
Kyle Rainsford
Victoria Hine
RBC
reopens some old
Ramsay
uncertainties. Victoria Hine and
Kyle Rainsford (Addleshaw Goddard) attempt to chart a course through.
Findings of fact are stubborn things: A Taxpayer v HMRC
Catrin Harrison
Dominic Lawrance
Dominic Lawrance and Catrin Harrison (Charles Russell Speechlys)
consider the implications of the Court of Appeal judgment.
Barclays’ tech outage: penalties, interest and HMRC’s constitutional boundaries
Jessica Kemp
Catherine Hill
The January Barclays tech outage shines a light on the sometimes uncompromising
interest and penalty regimes facing taxpayers which, in this context, demand
flexibility, write Jessica Kemp and Catherine Hill (White & Case).
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Yorkshire Agricultural Society, consistent interpretation and the continued relevance of EU law
Edd Thompson
Edd Thompson (Forvis Mazars) explores the Upper Tribunal’s approach to
the principle of ‘consistent interpretation’ on the VAT charitable fundraising
exemption and considers its potential relevance in the post-Brexit era.
Judicial review in tax disputes
Adam Craggs
Liam McKay
Adam Craggs and Liam McKay (RPC) set out the general principles and the
practical aspects of advancing a judicial review claim.
Helping vulnerable individuals: a guide for tax professionals
Dawn Register
Chris Holmes
How do you spot the signs, and what steps should you take? Chris Holmes and Dawn Register (BDO) provide a practical guide for tax advisers.
Transfer pricing: why returns are rarely risk-free
Phil Maggs
Phil Sneade
Phil Maggs and Phil Sneade (Frontier Economics) explain why it is usually wrong to argue for a ‘risk-free’ return for capital at arm’s length.
Go to page
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598
EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 10 October 2025
Government no closer on wealth tax
ATT launches MTD ‘digital readiness tips’ for agents
R&D claims down but support remains stable
Reactivating clients’ self-assessment accounts
CASES
Read all
GW Martin & Co Ltd and another v HMRC
A Weis v HMRC
Other cases that caught our eye: 10 October 2025
Isle of Wight NHS Trust v HMRC
Jumpman Gaming Ltd v HMRC
IN BRIEF
Read all
HMRC’s new NIC guidance on internationally mobile employees
The tax Budget cycle
More on s 455
What if HMRC win in Hotel la Tour?
Supreme Court in Prudential Assurance
MOST READ
Read all
HMRC’s new NIC guidance on internationally mobile employees
Jumpman Gaming Ltd v HMRC
Isle of Wight NHS Trust v HMRC
GfC 13 and the filing position: nothing to see here?
Legislating against promoters of marketed tax avoidance scheme