6/30/2026 9:50:45 AM Distributions from non-UK companies: aligning with UK companies By Alex Sim HMRC’s consultation on distributions includes a proposal to scrap a long-standing difference in tax treatment between distributions from...
6/30/2026 9:18:07 AM HMRC’s consultation on distributions: capital repayments and the end of the “New HoldCo” scheme? By Jamshed Bilimoria In the first post in this series, Zoe Andrews described HMRC’s consultation on modernising the taxation of distributions and repayments...
6/26/2026 2:13:04 PM Closer scrutiny: how the distributions consultation targets close companies By Stephanie Mullins While HMRC’s consultation on modernising the distributions rules looks only at income tax (and not corporation tax) treatment, this post...
6/26/2026 7:48:10 AM Tax-exempt demergers: relaxing the rules with some strings attached By Ed Milliner Amongst the more (generally) positive proposed changes being considered as part of HMRC's consultation on modernising the distributions...
6/24/2026 12:49:10 PM HMRC’s consultation on distributions: A fundamental reset? By Zoe Andrews Never a dull day in Tax! HMRC’s consultation on modernising the taxation of distributions and repayments of capital from companies, which...
6/16/2026 9:55:17 AM Challenging HMRC Information Requests: Lessons from Lifeplus By Stephanie Mullins The receipt or threat of an information notice from HMRC under Schedule 36 FA 2008 is commonly the point many tax departments reach for...
5/7/2026 1:49:35 PM No tax, no treaty exemption? Italian court denies exemption for untaxed gains By Michele Dimonte Can a taxpayer rely on a treaty exemption on the disposal of a shareholding if the gain is not taxed in the taxpayer’s state of...
4/22/2026 12:12:35 PM Burlington: taxpayer wins again in treaty purpose test case By Zoe Andrews In a decision of significance for the secondary debt market, the Court of Appeal in Burlington has unanimously dismissed HMRC’s appeal....
4/15/2026 3:11:46 PM Gunfleet Sands: Supreme Court rules on the limits of “expenditure on the provision of plant” By Zoe Andrews When is capital expenditure "on the provision of plant” for the purposes of section 11 Capital Allowances Act 2001? This was the question...
3/18/2026 3:14:40 PM Muller – how much of the "real world" should be imported into the notional UK resident company fiction? By Zoe Andrews There are many places in the UK tax legislation where deeming provisions are employed in order to apply the tax rules to particular...
12/17/2025 2:45:08 PM Hotel La Tour Supreme Court decision: no VAT recovery on share sale deal fees By Zoe Andrews The Supreme Court in Hotel La Tour has unanimously rejected the taxpayer’s appeal and determined that the input tax on deal fees...
11/26/2025 7:26:44 PM Smorgasbord not showstopper: the UK Budget 2025 By Nadia Hourihan Patrick Follan The November 2025 budget is here at last. During the months of speculation in the run-up to the big day, two possible futures emerged: a...
11/26/2025 6:34:00 PM Autumn Budget 2025: UK Listing Relief for Stamp Duty Reserve Tax By Kasim Mehmood Amidst the broader UK stamp taxes on shares modernisation efforts (discussed here and here), today in her Autumn Budget 2025, the...
10/2/2025 9:00:59 AM Civil and criminal investigations by HMRC: Drawing the line By Sarah Osprey Patrick Follan So far, our blog post series on tax disputes in the UK has focussed generally on enquiries and appeals processes. Here, we focus on...
9/30/2025 10:45:45 AM Appealing a UK tax case beyond the First-tier Tribunal: five points to consider By Sarah Osprey Amy Motherwell With HMRC statistics showing that HMRC was successful (at least in part) in 93% of First-tier Tribunal (FTT) tax cases in 2024/25, many...
9/25/2025 9:07:01 AM What happens when you take a UK tax dispute to the First-tier Tribunal? By Sarah Osprey Jamshed Bilimoria The First-tier Tribunal (FTT) is the first stage of the court process for appealing, for instance, a corporation tax assessment. The...