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COMPLIANCE
20 questions on QAHCs
Naomi Lawton
James Burton
Sorsha Reilly
James Burton, Naomi Lawton & Sorsha Reilly (Allen & Overy) provide a practical Q&A on the workings of the new regime that is designed to offer significant benefits to attract a wide range of investors and holding structures.
Tax considerations for M&A deals: due diligence and structuring
John Holt
Callum Grant
John Holt and Callum Grant (PwC UK) summarise the UK tax aspects of M&A transactions with a particular focus on acquisitions of high growth tech businesses.
Uncertain tax treatment: highlights from HMRC’s final guidance
Kate Alexander
Nick Evans
Kate Alexander and Nick Evans (Baker McKenzie) review the newly published
Uncertain Tax Treatments by Large Businesses Manual.
The plastic packaging tax: how it works
Ugo Onwumelu
Charlotte Sallabank
Charlotte Sallabank and Ugo Onwumelu (Katten Muchin Rosenman) explain key features of the new tax and how it will apply to businesses.
Early stage tax disputes: a practical guide
Sophie Lloyd
Rob Smith
A growing number of taxpayers can expect to be involved in ‘early stage’ tax
disputes over the coming years. Sophie Lloyd and Rob Smith (Travers Smith)
provide a practical guide for their advisers.
Does FATCA breach data protection? Jenny goes to court
Adam Rose
Filippo Noseda
Filippo Noseda and A
dam Rose (
Mishcon de Reya) discuss
the data protection repercussions of a system of automatic exchange of information in light of recent court decisions in the US and UK.
Consultation on the UK’s new mandatory disclosure rules
Veronica McMahon
Some of the definitions may have changed from DAC 6 to UK MDR, but the
concepts are broadly the same, writes Veronica McMahon (Osborne Clarke).
When is a defective HMRC notice invalid?
Sam Wardleworth
Steven Porter
Steven Porter and Sam Wardleworth (Pinsent Masons) examine recent cases that suggest a growing reluctance on the part of the courts to declare notices invalid for minor HMRC errors.
Contentious tax quarterly
Constantine Christofi
Robert Waterson
Recent trends in the contentious tax world, by Robert Waterson and Constantine Christofi (RPC).
HMRC’s draft guidance: adding further uncertainty to uncertain tax treatments
Kate Alexander
Nick Evans
It was hoped HMRC’s guidance would clarify the interpretation of the vaguer aspects of the statute, but the current draft offers limited practical assistance, write Kate Alexander and Nick Evans (Baker McKenzie).
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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
Tax Journal authors for March
HMRC closing in on tax avoidance (again)
Finance Act 2025 enacted
MPs press ahead with NICs increases
ATED chargeable amounts increased
CASES
Read all
HMRC v Innovative Bites Ltd and another
PD & MJ Ltd v HMRC
LR R&D LLP v HMRC
Other cases that caught our eye: 28 March 2025
Orsted West of Duddon Sands (UK) Ltd and others 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
Orsted West of Duddon Sands (UK) Ltd and others v HMRC
Concerns remain over Making Tax Digital
HMRC closing in on tax avoidance (again)
V Louwman v HMRC
B Lynch v HMRC