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ANALYSIS
Cutting edge analysis on tax issues.
Finance Act 2025: special report
Ros Martin
A detailed report of this year’s Finance Act.
FA 2025 review: VAT on private school fees: a lack of clarity
Etienne Wong
On its face, the new legislation imposing VAT on the provision of education by a private school seems straightforward well put-together, even. It takes little time to realise, however, that perhaps the Government should have taken a couple...
FA 2025 review: The loans to participators regime no more (re)paying your way
Hugh Gunson
With all the publicity that has surrounded other parts of FA 2025, practitioners could be forgiven for having missed the changes to the loans to participators regime tucked away in s 81. The rules: The loans to participators rules in...
FA 2025 review: Double remittances
Peter Vaines
Alarm has arisen over suggestions that a change introduced in the Finance Act will bring into charge to tax remittances of income or gains when money has been remitted by a person who is not resident, but for some reason is taken out of the UK and...
FA 2025 review: The new FIG regime: who are the real winners?
Jo Bateson
The new Foreign Income and Gains (FIG) regime comes into effect from 6 April 2025 which has been overshadowed by all the discussion on the abolition of the non-dom regime. We should be spotlighting the FIG regime which is attractive for...
FA 2025 review: EOTs: common sense prevails
Ritchie Tout
FA 2025 Sch 6 introduces some fundamental and far-reaching changes to the Employee Ownership Trusts (EOT) tax rules. HMRC view the changes as pure anti-avoidance to provide them with the tools to counter the undoubted abuse of the EOT tax...
FA 2025 review: Pillar Two: three things to note
Bezhan Salehy
FA 2025 includes various provisions connected to the UKs implementation of the OECD Pillar Two global minimum tax initiative. There are three main things to note: Undertaxed Profits Rule (UTPR): The main mechanism by which countries will...
Tax and the City review for April 2025
Zoe Andrews
Mike Lane
This month’s review by Mike Lane and Zoe Andrews (Slaughter and May)
considers the consultations on advance tax certainty for major projects and
on third party data.
The VAT review for April 2025
Katie Oliver
Gary Barnett
Katie Oliver and Gary Barnett (Simmons & Simmons) review the latest
decisions on VAT recovery and an AG opinion on the application of market
value provisions in the VAT Directive.
20 years of HMRC
Heather Self
Political pressure has resulted in HMRC adopting a slow and cautious decision-making process that remains to this day, writes Heather Self (Blick Rothenberg).
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 11 April 2025
HMRC confirm their view on double remittances
NICs (Secondary Class 1 Contributions) Act 2025 receives royal assent
HMRC Directions for internationally mobile employees
Loan Charge review: call for evidence
CASES
Read all
C Purkiss (as liquidator of Ethos Solutions Ltd) v T Kennedy and others
B Patel v HMRC
Other cases that caught our eye: 11 April 2025
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC’s whistleblower reward scheme: what we know so far
Private schools VAT challenge
Morgan Lloyd Trustees Ltd v HMRC
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way