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LITIGATION
Boulting: jurisdiction and the rule of law
Constantine Christofi
Robert Waterson
Adam Craggs
Adam Craggs, Robert Waterson and Constantine Christofi (RPC) examine the High Court decision that refused permission to bring a judicial review claim against HMRC.
AXA v Genworth: gross misunderstandings?
Helen Coward
Helen Coward (Charles Russell Speechlys) reviews a recent High Court case
on the meaning of a gross-up clause in a share purchase agreement.
Charman: old ERS law, new insights
Nigel Doran
Philip Swinburn
Nigel Doran and Philip Swinburn (Macfarlanes) examine the Upper Tribunal decision on the employment-related securities provisions of ITEPA 2003 Part 7.
Parry: pension transfers and omissions
Matthew Harrison
Matthew Harrison (Withers) examines the impact of a recent Supreme Court decision.
Contentious tax: quarterly review
Constantine Christofi
Adam Craggs
Recent trends in the contentious tax world, by Adam Craggs and Constantine Christofi (RPC).
Do HMRC’s allegations of fraud against GE signal a new era in tax investigations?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) examine
what is effectively the pilot episode for an upcoming courtroom drama.
Company residence
Jackie Wheaton
Jackie Wheaton (BDO) examines the case law in determining when a company is resident in the UK for tax purposes.
Tyrwhitt: when employees become partners
Dominic Stuttaford
Sofia Casselbrant
Dominic Stuttaford and Sofia Casselbrant-Multala (Norton Rose Fulbright)
review the NICs treatment of bonus payments by LLP to former employees
who subsequently become members.
Apple: the Commission fails to overcome its evidential burden
Tarlochan Lall
George Peretz KC
The General Court’s decision shows the difficulties the European Commission
faces in proving selective tax advantages that may constitute unlawful state
aid, write George Peretz QC and Tarlochan Lall (Monckton Chambers).
Negative earnings: how wide is their scope?
Nigel Doran
The scope of negative earnings is almost certainly wider than has generally
been appreciated, writes Nigel Doran (Macfarlanes).
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC