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Tax and the City Review - September 2025 In Currys, the FTT decides that the taxpayer had not disposed of the goodwill before leaving the chargeable gains group and so a degrouping charge under TCGA 1992 section 179 arose. HMRC plan to increase the compliance burden on financial institutions and...
BLOG: Can you rely on a tax treaty to progress an HMRC enquiry? If a tax treaty is engaged, it may be possible to ask HMRC to consider how that tax treaty will interact with the enquiry – that is what was said in the previous post of our series of blogs on tax disputes in the UK . Here, we consider...
BLOG: Bringing an HMRC enquiry to conclusion HMRC enquiries can be a frustrating process. There is no time limit for HMRC to complete an enquiry and enquires can continue for many years, with numerous requests for information. Compliance costs can mount and potentially awkward disclosures may need...
BLOG: Privilege in UK tax disputes: Five questions answered HMRC cannot demand disclosure of documents that are subject to legal professional privilege. However, it is not uncommon for HMRC to ask for them. Careful thought is required when assessing if a document really is privileged (and so can be withheld) and,...
BLOG: Supreme Court in Prudential Assurance clarifies interaction of VAT grouping and time of supply rules Imagine a scenario where two companies are in a VAT group and one supplies investment management services to the other. Consideration for the services comprises a quarterly management fee and success fees. The success fees depend on investment performance...
BLOG: How to respond to information requests from HMRC A notice of enquiry will almost always be accompanied by a request for information. In the previous blog of this series on tax disputes in the UK, we discussed what to look out for when HMRC open an enquiry – and noted that enquiries often...
Podcast: Tax News: September 2025 Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area.
Podcast: Tax News: July 2025 Zoe Andrews and Tanja Velling discuss the following recent cases:
Tax and the City Review - July 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: The Upper Tribunal’s decision in Osmond, in favour of the taxpayers, that the income tax advantage was an effect, not a main purpose, of the transaction and so the transactions...
BLOG: There’s only one POEM – but it’s not of the rhyming sort! The purpose of a double tax treaty is to allocate taxing rights between the parties to the treaty in a way which avoids double taxation. As taxing rights of a party often depend on the place of residence of the taxpayer, it is important that a treaty has...
Podcast: Insurance in focus: From Decline to Demand – The Evolving UK Annuities Market In the fourth episode of 'Insurance in focus' Jonathan Marks, Nick Pacheco and Sarah Osprey discuss:  Recent increases in sales of individual annuities The broader market including the bulk annuity market  Related...
Tax News: The One Big Beautiful Bill In this special episode of our Tax News podcast, Zoe Andrews and Tanja Velling are joined by Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, to discuss the significant impact the proposed section 899 could have on US capital markets.
BLOG: UK Supreme Court in Dolphin Drilling decides that the meaning of “incidental” depends on statutory context The Supreme Court in Dolphin Drilling dismissed the taxpayer’s appeal, agreeing with the Court of Appeal that the provision of accommodation for offshore workers was an independent end in itself and not (as the First-tier Tribunal and Upper Tribunal had...
Tax and the City Review - June 2025 In their latest Tax and the City article, Mike Lane and Zoe Andrews consider: The test of whether foreign dividends received by an individual are income or capital as applied by the Court of Appeal in Alexander Beard. The Upper Tribunal’s decision in...
Podcast: Tax News: June 2025 Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in Walkers Snack Foods on the VAT classification of “Sensations Poppadoms” and Rettig Heating Group, the judicial review of HMRC’s refusal of a late claim to set off a non-trading loan...