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ANALYSIS
Cutting edge analysis on tax issues.
Private client tax in 2024: ch-ch-ch-changes*
Alyssa Haggarty
Claire Weeks
Changes to non-doms and IHT have dominated the year, but there have also been some interesting cases, write Claire Weeks and Alyssa Haggarty (Maurice Turnor Gardner).
The contentious tax world in 2024
Adam Craggs
Liam McKay
This year has seen decisions on anonymity in tax appeals, cross-examination in judicial review, and failing to comply with tribunal directions. Adam Craggs and Liam McKay (RPC) investigate.
Looking back on 2024: a VAT retrospective
Etienne Wong
There was only one VAT news story in 2024: the taxing of private school education. Etienne Wong (Old Square Tax Chambers) also looks at some of the other notable developments along the way.
The Scottish Budget 2025/26: steady as she goes, but with some stings in the tail
Alan Barr
Isobel d'Inverno
Isobel d’Inverno and Alan Barr (Brodies) review the Scottish Budget, including the new
Scotland’s tax strategy
publication which contains a wide range of substantive possibilities for change.
In conversation with... Malcolm Gammie CBE KC
Anthony Inglese
Malcolm Gammie CBE KC
Malcolm Gammie CBE KC (One Essex Court) is a widely respected silk with extensive experience in tax litigation and advisory work, having represented both HMRC and taxpayers in a number of high-profile tax cases. He talks to Anthony Inglese about life at the Tax Bar and beyond.
The tractor tax
Stuart Maggs
The proposed IHT reforms seem to attack the farmers they should protect and
protect the people they should tax, writes Stuart Maggs (Howes Percival).
A third route to exit: tax consequences of continuation fund transactions
May Smith
Emily Szasz
May Smith and Emily Szasz (Freshfields) examine some of the key
tax considerations that arise in relation to the transfer of assets into a
continuation fund.
The Foreign Income and Gains regime: employer considerations
Nisus Larsen
Claire Murray
The UK is likely to become more attractive in the short term for overseas
employees but less attractive in the medium to long term, Claire Murray and
Nisus Larsen (Alvarez & Marsal) explain.
Dealing with non-resident CGT issues on transactions
Akash Mehta
Jenny Doak
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key
considerations for M&A transactions.
Insuring M&A tax risks: practical considerations for buyers
Shayaan Zaraq Bari
Nicholas Gardner
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining
W&I insurance with other tools may help bridge any gaps in tax risk coverage
and maximise protection for buyers.
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416
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