7/9/2026 1:54:07 PM A new criminal offence for reckless untrue statements in direct tax By Kate Ison Jackelyn West The Government has published a consultation on a proposal to introduce a new criminal offence for making reckless untrue statements or...
7/3/2026 2:01:07 PM Supreme Court decides the LLP salaried member rules - but sends BlueCrest back to the First-tier Tax Tribunal By Sarah Ling James McCredie Gideon Sanitt Rhiannon Kinghall Were Bezhan Salehy +2 more... Show less The Supreme Court has handed down its long-awaited decision in HMRC v BlueCrest Capital Management (UK) LLP, dismissing the taxpayer's...
6/26/2026 1:30:36 PM European Commission's tax simplification package and the future of the Unshell substance tests By Rhiannon Kinghall Were Milly Walker The European Commission has adopted its long-anticipated tax simplification package, comprising a direct taxation “Omnibus” Directive and...
6/23/2026 5:07:37 PM Returning value to UK shareholders: HMRC consults on significant tax changes By Sarah Ling Gregory Price Rhiannon Kinghall Were Milly Walker +1 more... Show less HMRC have today published a consultation on a significant modernisation of the UK tax rules for distributions and capital repayments by...
6/23/2026 11:02:07 AM LLP profit-sharing arrangements and miscellaneous income: Supreme Court rules in HFFX By Joe Robinson Rhiannon Kinghall Were The Supreme Court has now handed down its judgment in HMRC v HFFX LLP; Atkins & Ors v HMRC [2026] UKSC 17. This case provides guidance on...
6/22/2026 4:16:37 PM Employment tax update - June 2026 By Robert Collard Lika Jatoeva This bulletin follows the release of the April and May Agent Updates (Issue 142 and Issue 143). In this issue we cover the content most...
6/17/2026 2:15:06 PM The Bank of England’s private capital SWES test – a blueprint for global regulators? By Rhiannon Kinghall Were Michael Sholem Lora Froud Steven Koppenaal +1 more... Show less As private credit plays an increasing role in the financial system, its rapid growth, tighter credit conditions and the heightened...
6/17/2026 1:27:06 PM Co-investment in private credit: structuring and fee considerations for sponsors By Harriet Miller Adam Caines Sophie Donnithorne-Tait Chris Daniel Pete Chapman Charishma Bhujohory +3 more... Show less As private credit has matured, investor demand for co-investment opportunities has increased significantly and co-investment has become...
6/16/2026 2:56:07 PM Beyond cost-plus: what the OECD's new approach to intra-group services means for UK taxpayers By Wai Wan Bahar Eken On 1 June 2026, the OECD published a consultation document proposing significant revisions to Chapter VII of the OECD Transfer Pricing...
6/12/2026 12:06:08 PM UK Government launches consultation on solving the LLC double taxation problem By James McCredie Alex Jones Andrew Crozier Bezhan Salehy Maudie Leach +2 more... Show less The UK Government has published a consultation on a legislative solution to deal with double tax issues which can arise where UK resident...
5/15/2026 10:04:07 AM Relying on a tax treaty is not an abuse of law: lessons from the Lehman litigation By Elizabeth Keeling HMRC v Burlington Loan Management is an important Court of Appeal decision on the interpretation of double tax treaty anti-abuse articles...
5/6/2026 11:45:07 AM M R Currell Limited: a cautionary tale for HMRC By Kate Ison Sophie Rhind Tackling disguised remuneration (DR) has long been a focus for HMRC, and they have had significant success in the area, protecting...
4/29/2026 11:01:00 PM Evergreen fund models – comparative analysis By Pete Chapman Chris Daniel Richard Fletcher Lora Froud Christopher Good Harriet Miller Ryan Moore Stephen Ross +5 more... Show less We have advised on the launch of a significant number of evergreen funds in recent years, particularly in the private credit space. In...
4/23/2026 11:45:37 AM Tax investigations and disputes newsletter - April 2026 By Gideon Sanitt Kate Ison Sarah Ling Jackelyn West +1 more... Show less Spring has arrived, and with it a fresh burst of activity from HMRC and the Tax Tribunals. HMRC's compliance toolkit continues to...
4/22/2026 1:52:37 PM Three’s a crowd: HMRC’s approach to employee share plan arrangements in practice By Gideon Sanitt Robert Collard Jackelyn West We have seen a notable rise in HMRC targeting what may be regarded as relatively innocuous employee share plans under the so-called...
4/17/2026 9:45:07 AM Close companies, open books: HMRC consults on new reporting requirements for close companies By Sarah Ling Rhiannon Kinghall Were Vitalii Trachuk On 19 March 2026, HMRC published a consultation document titled "Reporting company payments to participators – modernising the reporting...