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Private client review for February 2026
Sophie Dworetzsky
Retrospective changes to the Temporary Repatriation Facility, updated FIG guidance and new AI guidance for advisers feature in this month’s review by Sophie Dworetzsky (Lombard Odier).
HMRC’s priorities for 2026: building for the future
Jonathan Athow
Jonathan Athow, HMRC’s Director General for Customer Strategy
and Tax Design, outlines the department’s digital transformation plans,
compliance strategy and modernisation agenda for the year ahead.
R&D tax in 2025: the calm after the storm?
Jenny Tragner
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.
End of year musings on corporate tax
Jenny Doak
Jenny Doak (Paul Hastings) contrasts a year of relative domestic stability with
international upheaval.
A year at the Tax Bar in 2025
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.
How AI could change the interpretation of public CbCR data
William H. Morris
As public CbCR regimes expand, AI tools could be used to reveal patterns in
global tax data, writes Will Morris (PwC).
AI in a new tax (3.0) world
Conrad Young
Tax technology adviser Conrad Young considers AI's rapidly increasing role for tax authorities and tax market participants.
Transformation Roadmap
Paul Aplin OBE
HMRC’s new roadmap heralds a step-change in the department’s digital
ambition, writes Paul Aplin OBE.
HMRC, tax disputes and AI
Liesl Fichardt
Emily Au
Will AI make tax disputes faster and smarter, or simply more complicated?
Liesl Fichardt and Emily Au (Quinn Emanuel) investigate.
Other cases that caught our eye: 6 February 2026
HICBC and taxpayer’s use of AI: In R Huish v HMRC [2026] UKFTT 129 (TC) (16 January), the FTT allowed the taxpayer’s appeal against discovery assessments purportedly charging him to the high income child benefit charge (HICBC) for 2015/16. HMRC made...
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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
UK posts record January budget surplus following increased tax receipts
HMRC guidance on R&D relief in the creative sector
Deferred remuneration for globally mobile employees
New guidance on registering for VAT IOSS scheme
Devolved Scottish Aggregates Tax to take effect from 1 April 2026
CASES
Read all
Lycamobile UK Ltd v HMRC
A Ferguson and another v HMRC
Genuine Care Homecare Services Ltd v HMRC
Other cases that caught our eye: 27 February 2026
MWL International Ltd
IN BRIEF
Read all
Crypto things
Tax efficient trust planning with surplus income
Suspended penalties
The Supreme Court hearing in Orsted Sands
Concerns over the scope of new conduct rules for advisers
MOST READ
Read all
Exchequer Secretary defends tax adviser registration regime as Law Society warns of market impact
Mandatory agent registration: what we know so far
Deductions after AD Bly: a shortcut for remuneration or pension provision?
Alimahomed: the Upper Tribunal gives ‘remittance’ a real world interpretation
Consultation tracker