Tax Journal

Market leading insight for tax experts
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Is the UK’s domestic Permanent Establishment definition reform fair, simple and supportive of growth, or is it, in reality, yet further complexity, asks Nick Thornton (Fried Frank).
HMRC’s increasing focus on upstream compliance and a more data-led, riskbased approach marks a clear shift away from the traditional enquiry cycle, as Vicky Topps and Karmjit Mader (KPMG) explain.
Paul Farey (AECOM) reviews the new rules and HMRC’s guidance.
From AI in court to IHT and judicial review, Sophie Dworetzsky (Lombard Odier) reviews the latest developments.
Dulcie Daly (Goodwin) considers the complexities that can arise for taxpayers when share sale proceeds include deferred amounts.

Henry Bennett-Gough (Simmons & Simmons) examines the Upper Tribunal’s decision in Boston Consulting Group and its implications for mixed member LLP structures.
AI could dramatically expand the scope of public engagement with tax policy, writes Dr Stephen Daly (King’s College London).
Mike Lane and Zoe Andrews (Slaughter and May) review recent developments including Sintra Global, tax adviser registration and HMRC’s large business compliance approach.
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