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Tax policy & administration
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Tax policy & administration
TAX POLICY ADMINISTRATION
How close is close enough? Orsted and the limits of ‘on the provision of plant’
Paul Farey
Paul Farey (AECOM) assesses how the Supreme Court’s stricter approach narrows the scope for capital allowances on preparatory expenditure.
Strike-out!
Glyn Edwards
Glyn Edwards (MHA) examines an apparent increase in HMRC strike-out applications and why many are failing to clear the tribunal’s high threshold.
Beyond ten years: rethinking EMI options
Nigel Watson
Claire Withers
Nigel Watson and Claire Withers (Burges Salmon) consider the extension of EMI option terms to 15 years and the practical implications for plan design, legacy options and compliance.
Uncertain tax treatments consultation: extending uncertainty?
Jack Prytherch
Yousuf Chughtai
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
Nigel Doran
Lika Jatoeva
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
Thomas Peet
Rob Sharpe
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.
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EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
NEWS
Read all
Effective consultation supports coherent and coordinated tax reform, says CIOT
Chancellor reportedly rejects alignment of CGT and income tax rates
CIOT seeks clarity on interest relief after capital withdrawals
HMRC launch online service for climate change levy returns
Consultation on plastic packaging tax
CASES
Read all
J Smith v HMRC
J Smith v HMRC
The Nigel Blackwell Family Trust and others v HMRC
Other cases that caught our eye: 16 October 2026
HMRC v British Airways plc
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
Read all
Victoria Oil & Gas plc v HMRC
Bolt: Supreme Court refuses permission to appeal
Loans to participators: s 455
AI and the unwinnable case
Modernising the taxation of distributions