Tax News

In this month's episode, Tax associate Stephanie Mullins joins Zoe Andrews to discuss:

In this month's episode, Tax associate Amy Motherwell joins Zoe Andrews to discuss:

For this month’s edition, Gabrielle Pereira and Alex Dustan join Zoe Andrew to discuss:

For this month’s edition, Ed Milliner joins Zoe Andrews to discuss three cases: Sintra (CA) – burden of proof in tax penalty appeals, Lycamobile (UT) – VAT on bundle plans (and two perfect quotes about VAT…), and Muller (CA) – how the partnership notional company fiction interacts with the intangible fixed assets rules.

The podcast then covers various UK tax developments including: tax adviser registration rollout with proposed delay for in house teams in the financial services industry, NAO report on taxing large businesses, and uncertain Tax Treatment consultation on extending the notification regime – including a possible new trigger where HMRC’s position is not known and there is more than one credible legal interpretation.

For this month’s edition, Jamshed Bilimoria joins Zoe Andrews to discuss three cases: Hotel La Tour (Supreme Court judgment on input VAT recovery on deal fees), Tower One St George Wharf (Court of Appeal decision on SDLT and anti‑avoidance) and Font (High Court decision on judicial review in MAP dispute).

The podcast then covers aspects of the Autumn Budget and Finance Bill including: mandatory tax adviser registration, SDRT exemption for newly listed companies, reform of transfer pricing, and permanent establishment (PE) rules; and the new corporation tax charge replacing DPT and changes to the share for share exchange rules and the impact on clearances.

Jamshed and Zoe go on to explore international developments in two areas: the OECD’s global minimum tax “side‑by‑side package” (including new safe harbours and simplification measures) and the OECD updates on global mobility, including when home‑working may (or may not) create a PE.

For this month’s edition, Alex Sim joined Zoe Andrews to discuss three cases of the FTT: Dialog (the tax treatment of break fees), Boulting (purchase of own shares was not a distribution) and Ferrero (the VAT treatment of Nutella biscuits). 

Sarah Osprey joined Zoe Andrews and Tanja Velling to discuss trends in HMRC enquiries and the use of criminal investigation powers in a tax context.

The podcast then covers the Supreme Court’s decision in Prudential Assurance on the interaction between the VAT grouping and time of supply rules, and the CJEU’s decision in Arcomet Towercranes that transfer pricing adjustments can trigger VAT liabilities.

Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area.

The podcast further covers three decisions of the First-tier Tribunal:

Zoe and Tanja go on to discuss L-Day materials including draft legislation for inheritance tax on inherited pension and death benefits, HMRC’s increased powers to close in on promoters, and the mandatory registration requirement for tax advisers interacting with HMRC, as well as certain other UK and international tax developments.

Zoe Andrews and Tanja Velling discuss the following recent cases:

The podcast also covers HMRC’s new guidance on advance pricing agreements for cost contribution arrangements, the government’s recently published tax policy making principles, Revenue & Customs Brief 4 (2025) on input tax recovery in respect of investment and administration costs linked to occupational pension funds and what’s next for Pillar Two.

Zoe Andrews and Tanja Velling are joined by Arvind Ravichandran, Tax Partner at Cravath, to discuss the impact the proposed section 899 could have on US capital markets if enacted but how it is unlikely to be a big issue in practice.

They cover: