Tax Journal

Rupert Shiers

Katharine Crossman

Rupert Shiers and Katharine Crossman (Hogan Lovells Cadwalader) examine the Supreme Court ruling on the deductibility of payments to address potential punishment for statutory and other breaches.

Nick Thornton

Nick Thornton (Fried Frank) challenges HMRC’s refusal to provide nonstatutory clearances on purportedly factual questions.

Mike Lane

Zoe Andrews

Mike Lane and Zoe Andrews (Slaughter and May) review ScottishPower, the Budget’s business tax measures, proposals to simplify the unallowable purpose rule and revised procedures for treaty relief on overseas interest payments.

Barbara Bento

Antony Greenwood

Barbara Bento and Antony Greenwood (Buzzacott) explain why Harte prevents HMRC from using one deliberate error to extend the assessment time limit for unrelated inaccuracies in the same tax year.

Irena Scullion

Julia Kal

The remote gaming duty freeplay rules are to be amended from 1 April 2027. However, the ruling in Jumpman Gaming remains relevant to historic assessments and repayment claims. Irena Scullion and Julia Kal (Grant Thornton) examine the judgment and also consider lessons for the VAT treatment of loyalty points.

Tom Margesson

Elena Rowlands

Tom Margesson and Elena Rowlands (Travers Smith) consider the plans for a new tax regime for sovereigns from 1 January 2029.

Hannah Magee, Charlotte Senior, Martin Verrall

Hannah Magee and Charlotte Senior (Grant Thornton) assess the proposed 10% Founders’ Relief and reduced BADR lifetime limit, highlighting restrictive eligibility tests and the importance of sale timing and deal structure.

Aparna Nathan

Aparajita Arya

Aparna Nathan KC and Aparajita Arya (Devereux Chambers) review when the FTT can hear public law arguments and explain how taxpayers can preserve their position through protective judicial review proceedings where jurisdiction is uncertain.