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IPT
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CROSS-BORDER
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Gerald Montagu (Gide Loyrette Nouel) examines the First-tier Tribunal
decision in
Lloyds Asset Leasing Ltd
.
Lloyds Asset Leasing Ltd v HMRC
FTT denies cross-border group relief claim on main purpose grounds.
FASTER: a European Withholding Tax Directive
Reinhart Devisscher
Paul Radcliffe
After ten compromise texts and two years of political debate, agreement has finally been reached on new rules for EU withholding tax procedures. Paul Radcliffe and Reinhart Devisscher (EY) examine the detail and consider what’s next.
The VAT review for November 2023
Katie Oliver
Gary Barnett
This month’s review by Katie Oliver and Gary Barnett (Simmons & Simmons) covers the Supreme Court decision in
Target Group
, the CJEU ruling on ‘free gift’ promotions, the potential use of split payments in the collection of VAT and the draft legislation intended to ensure stability on the interpretation of VAT and excise laws.
Impact Contracting Solutions Limited v HMRC
Can HMRC rely on a principle of EU law to cancel a VAT registration?
Dicey Rule 3: the Court of Appeal’s decision in Skat v Solo
Dilpreet K. Dhanoa
Philip Baker KC
The Court of Appeal has upheld SKAT’s claims. Philip Baker QC and Dilpreet K. Dhanoa (Field Court Tax Chambers) analyse whether, from a legal and international tax perspective, this was the correct decision.
DAC 6 update: UK narrows scope of mandatory reporting
Sandy Bhogal
Avi Kaye
Sandy Bhogal and Avi Kaye (Gibson, Dunn & Crutcher) explain the extent to which the UK government has curtailed existing reporting obligations.
Key issues for in-house tax teams: a checklist
Mark Ellis
James Egert
Chris Holmes
Chris Holmes, Mark Ellis and James Egert (BDO) set out important current corporate and employer tax issues which in-house tax teams should now be addressing.
HMRC’s final guidance on DAC 6: a good first attempt?
Helen Buchanan
John Tolman
Helen Buchanan and John Tolman (Freshfields Bruckhaus Deringer) discuss the published guidance that still leaves many key questions around the scope of DAC 6 reporting obligations.
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.
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EDITOR'S PICK
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
1 /7
Understanding the FIG regime
Jo Bateson
2 /7
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
3 /7
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
4 /7
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
5 /7
Tax odyssey: the journey to a single securities tax
Naomi Lawton
6 /7
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
7 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
Enhancing UK tax policy: a blueprint for supporting technological innovation
Dominic Mathon
,
Kate Murphy
Carried interest tax reform: next steps
Damien Crossley
,
Bezhan Salehy
The new UK PE, TP and UTPP rules: key questions
Mark Bevington
Tax odyssey: the journey to a single securities tax
Naomi Lawton
Closing in on promoters of marketed tax avoidance scheme
Malcolm Gammie CBE KC
NEWS
Read all
HMRC manual changes: 18 July 2025
Chancellor outlines financial services strategy
CIOT reviews transfer pricing proposals
Marriage allowance: backdating claims
Further HMRC update on VAT penalties
CASES
Read all
Abbotsford Property Group Ltd and another v Revenue Scotland
R (oao Thomas Holdings Ltd and others) v HMRC
G Stenhouse and another v HMRC
Other cases that caught our eye: 18 July 2025
B D’Angelin v HMRC
IN BRIEF
Read all
HMRC’s approach to wealthy individuals
There’s only one POEM
Discovery assessments: agents
Standish v Standish
Section 899 compromise shifts international tax landscape
MOST READ
Read all
‘Legislation Day’ date announced
One Big Beautiful Bill Act enacted
Wealth taxes and fiscal reality
G Haworth and others v HMRC
OBBBA: permanent tax cuts and international adjustments