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TAX POLICY ADMINISTRATION
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).
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.
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Ask an expert: Dividend planning under the new close company reporting regime
Consultation tracker
IHT replacement property relief restrictions