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Tax policy & administration
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TAX POLICY ADMINISTRATION
Carried interest: the L-day changes
Bezhan Salehy
Damien Crossley
The draft Finance Bill provisions seek to address some of the issues for credit
funds, write Bezhan Salehy and Damien Crossley (Macfarlanes).
Legislation day 2025: Requirement for advisers to register with HMRC
David Whiscombe
Worse than useless?
Close encounters with close companies (part 1): definitions and concepts
Hannah Manning
Ross McGregor
In the first of two articles examining the close companies rules, Hannah
Manning and Ross McGregor (Travers Smith) explain why it should not be
assumed that a company is not close without looking carefully at the relevant
legislation.
Carry on paying on account (or risk paying more)
Ceinwen Rees
Frankie Beetham
The newly reformed tax on carried interest will subject carried interest to the
payments on account regime. Ceinwen Rees and Frankie Beetham (Kirkland
& Ellis) set out some of the key practical considerations.
BGC Services: lacking determination
Matthew Greene
Guy Bud
Matthew Greene and Guy Bud (Stewarts) examine a recent tribunal decision
which stresses the need for accountability and transparency from HMRC
when issuing determinations.
Rettig: HMRC’s tactical approach to public law challenges
Richard Doran
John Hayton
Principled positions often adopted by HMRC can have the practical effect of
avoiding or otherwise delaying judicial scrutiny of their decision-making process,
write Richard Doran and John Hayton (Joseph Hage Aaronson & Bremen).
It’s Consultation, Jim – but not as we know it...
Chris Sanger
At first glance, the Government’s revised approach to tax policy making retains
much of the existing framework. There is, however, a significant change on the
commitment to consultation, writes Chris Sanger (EY).
The trials and tribulations of interest withholding tax
Bezhan Salehy
Elvira Colomer Fatjo
Rebecca Rose
Bezhan Salehy, Rebecca Rose and Elvira Colomer Fatjo (Macfarlanes)
take a practical look at UK interest withholding tax, highlighting common
compliance pitfalls, HMRC’s approach and emerging complexities.
Keeping the receipts: HMRC’s burden in company insolvencies
Liesl Fichardt
Emily Au
HMRC’s preferential ranking brings into sharp focus their requirements to
evidence and substantiate their claims in an insolvency, as Liesl Fichardt and
Emily Au (Quinn Emanuel) explain.
The VAT review for July 2025
Gary Barnett
Jo Crookshank
This month’s review by Jo Crookshank and Gary Barnett (Simmons &
Simmons) covers recent decisions on the single/multiple supply rule and the
VAT finance intermediation exemption, as well as HMRC’s change of policy on
pension scheme costs.
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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