ANALYSIS

Cutting edge analysis on tax issues.

Jennifer Tragner (S&W) considers an unsettled year for R&D reliefs, where transitional rules, evolving guidance and emerging AI questions kept advisers busy despite few new policy changes.

Rachel de Souza

Rachel de Souza (RSM UK) charts a tumultuous year for international private clients, as sweeping changes to domicile, offshore trusts and IHT prompted unprecedented restructuring – and, for some, departure from the UK.

Jenny Doak

Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with international upheaval.

David Yates

David Yates KC (Pump Court Tax Chambers) reflects on a year marked by unpredictable litigation, shifting private client rules and the evolving realities of practice at the Tax Bar.

Adam Craggs

Liam McKay

Adam Craggs & Liam McKay (RPC) report a year marked by tighter procedural frameworks, clarifying case law and an intensified HMRC focus on both avoidance and criminal activity.

Philippe Gamito

Philippe Gamito (Baker McKenzie) examines a year of significant VAT case law, from transfer pricing adjustments and debt-collection boundaries to the evolving scope of insurance and credit intermediation.

Anthony Inglese

Ray McCann

Ray McCann, author of the recent loan charge review, talks to Anthony Inglese about the moments that shaped his approach to tax for half a century.

David Pett

All but one of the loan charge review’s ‘hard’ recommendations have been accepted. David Pett (Temple Tax Chambers) assesses both the review and the Government’s response – and considers the implications for affected taxpayers and the new settlement opportunity.

Peter North

Rob Sharpe

Rob Sharpe and Peter North (Cleary Gottlieb) examine a recent Upper Tribunal ruling on the taxation of stock appreciation rights – a decision that introduces fresh uncertainty for arrangements falling outside ITEPA 2003 Part 7.

Katie Oliver

Gary Barnett

Katie Oliver and Gary Barnett (Simmons & Simmons) review recent VAT developments on factoring, public bodies, input VAT evidence and intermediaries’ recovery rights.

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