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COMPANY-RESIDENCE

UK central management established Bermudan company’s residence: In Cogefin (Bermuda) Ltd and another v HMRC [2026] UKFTT 1108 (TC) (30 July), the FTT upheld HMRC’s discovery assessments, finding that the Bermuda-incorporated company was UK resident...

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Kyle Rainsford

Kyle Rainsford (Travers Smith) examines the ramifications of the Upper Tribunal’s decision.

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Helen Coward

The Court of Appeal rules against the taxpayer in a company tax residence dispute but the scope of the judgment is limited.

EDITOR'S PICK

Budget 2026: protecting the UK’s tax competitiveness

Budget 2026: protecting the UK’s tax competitiveness

David Gordon

The Orsted ‘tax nothing’

The Orsted ‘tax nothing’

Andrew Page

Budget 2026: options for taxing wealth

Budget 2026: options for taxing wealth

Dom Rothbarth

HMRC powers and the taxpayer relationship: when is enough, enough?

HMRC powers and the taxpayer relationship: when is enough, enough?

Chris Sanger , Constantine Christofi , Craig Kirkham-Wilson

Redrawing the line: modernising the taxation of distributions

Redrawing the line: modernising the taxation of distributions

Jill Gatehouse , Emily Szasz , Joe Williams , Tom Gardner

Reckless tax statements: a lower threshold for crime?

Reckless tax statements: a lower threshold for crime?

Adam Craggs , Tom Jenkins

Permanent Establishment exemption: preparing for mandatory application

Permanent Establishment exemption: preparing for mandatory application

Alison Lobb , Lisa Shipley

Budget 2026: protecting the UK’s tax competitiveness

Budget 2026: protecting the UK’s tax competitiveness

David Gordon

The Orsted ‘tax nothing’

The Orsted ‘tax nothing’

Andrew Page

Budget 2026: options for taxing wealth

Budget 2026: options for taxing wealth

Dom Rothbarth

HMRC powers and the taxpayer relationship: when is enough, enough?

HMRC powers and the taxpayer relationship: when is enough, enough?

Chris Sanger , Constantine Christofi

Redrawing the line: modernising the taxation of distributions

Redrawing the line: modernising the taxation of distributions

Jill Gatehouse , Emily Szasz

Reckless tax statements: a lower threshold for crime?

Reckless tax statements: a lower threshold for crime?

Adam Craggs , Tom Jenkins

Permanent Establishment exemption: preparing for mandatory application

Permanent Establishment exemption: preparing for mandatory application

Alison Lobb , Lisa Shipley

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