TAX POLICY ADMINISTRATION

Jivaan Bennett (Temple Tax Chambers) reviews the substantive amendments to the Model Convention – concerning home-office PEs, associated companies and more – and what it could mean for UK DTT interpretation.

Lisa Shipley Alison Lobb Ed Wright

Alison Lobb, Lisa Shipley and Ed Wright (Deloitte) outline the Inclusive Framework’s much-awaited ‘side-by-side’ package.

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.

John Barnett

The Government’s approach to APR and BPR reform combines delay and anti-forestalling in a way that risks serious unintended consequences, writes John Barnett (CIOT).

Zoe Andrews

Nadia Hourihan

Zoe Andrews and Nadia Hourihan (Slaughter and May) offer a whirlwind review of 2025’s tax highlights and curiosities.

Heather Self

Heather Self (Blick Rothenberg) praises greater HMRC transparency while warning of deepening fiscal drag and policy inconsistency.

Stuart Maggs

This year has been a roller-coaster, writes Stuart Maggs (Howes Percival).

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.

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.

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.

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