Tax Take

Thinking - Blog

HMRC issues guidance on new Prohibition of Promotion regime

Published on 09 October 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Liam McKay, Of Counsel

Man using his phone in futuristic setting

HMRC has issued guidance on the new Prohibition of Promotion (POP) regime contained in Part 6 of the Finance Act 2026, highlighting the significant penalties that can apply to those who promote certain tax avoidance arrangements.

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Thinking - Blog

HMRC's New Anti-Avoidance Information Powers

Published on 08 October 2026. By Liam McKay, Of Counsel

Signpost pointing in different directions

HMRC has published guidance on the new anti-avoidance information notices (AAINs), contained in Part 6 of the Finance Act 2026. The new powers give HMRC significantly broader information-gathering powers when investigating the promotion or facilitation of tax avoidance.

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Thinking - Blog

UK prize draws: HMRC scrutiny of VAT treatment

Published on 06 October 2026. By Michelle Sloane, Partner and Jasprit Singh, Senior Associate

Bank notes

HMRC is scrutinising the VAT treatment adopted by operators of prize draws offering both paid and free entry routes.

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Thinking - Blog

Upper Tribunal dismisses HMRC's appeal and confirms that taxpayers were carrying on a business with a view to profit

Published on 01 October 2026. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

In HMRC v GCH Corporation Ltd and others [2026] UKUT 00219 (TCC), the Upper Tribunal dismissed HMRC's appeal and confirmed that GCH Active LLP was carrying on a business with a view to profit, for the purposes of section 59A, Taxation of Chargeable Gains Act 1992, at the time certain loan notes were transferred to it. As the requirements of section 59A were satisfied, the transfers were capital contributions, rather than disposals, and no Chargeable Gains Tax liability arose.

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Thinking - Publication

Tax Bites - October 2026

Published on 30 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Daniel Williams, Associate

Man on the phone

Welcome to our October 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Thinking - Blog

HMRC’s new anti-avoidance information notice powers

Published on 24 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Liam McKay, Of Counsel

Stylish woman using tablet

HMRC has published guidance on the new anti-avoidance information notices (AAINs), contained in Part 6 of the Finance Act 2026. The new powers give HMRC significantly broader information-gathering powers when investigating the promotion or facilitation of tax avoidance.

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Thinking - Blog

UT remits £880m loan relationship dispute back to the FTT

Published on 24 September 2026. By Daniel Williams, Associate

Signpost pointing in different directions

In Barclays Bank plc v HMRC [2026] UKUT 212, the Upper Tribunal held that the First-tier Tribunal had erred in law when determining whether £3 billion paid for reserve capital instruments was attributable wholly to those instruments or partly to warrants issued by Barclays plc, as it had taken into account irrelevant considerations. The Upper Tribunal remitted the case back to the First-tier Tribunal to reconsider its decision.

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Thinking - Publication

VAT update September 2026

Published on 23 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Jasprit Singh, Senior Associate

Woman shopping

Welcome to the September 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.

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Thinking - Blog

UK ‘Windfall’ Bank Tax Would Worsen an Already Complex System

Published on 17 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Jasprit Singh, Senior Associate

Signpost pointing in different directions

Adam Craggs and Jasprit Singh consider the impact of a new tax on UK banks.

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Thinking - Blog

Tribunal limits HMRC's Schedule 36 powers in transfer pricing case

Published on 10 September 2026. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

Tax Tribunal allow taxpayer's appeal against a Schedule 36 information notice, issued by HMRC in a transfer pricing enquiry, as the documents requested were not reasonably required to check the taxpayers tax position and in any event were not in the taxpayer's possession or power.

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Thinking - Blog

HMRC prevented from imposing late payment penalties following reallocation of earlier payments made on time

Published on 03 September 2026. By Daniel Williams, Associate

Signpost pointing in different directions

In Herrmann v HMRC [2026] UKFTT 715 (TC), the First-tier Tribunal allowed the taxpayer’s appeals, holding that subsequent reallocation of payments could not, retrospectively, create late payment where the relevant tax had been paid by the statutory trigger dates and HMRC could not issue late payment penalties and surcharges under paragraphs 1-3, Schedule 56, Finance Act 2009 and section 59C, Taxes Management Act 1970.

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Thinking - Blog

Is HMRC looking at your crypto activity?

Published on 03 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Liam McKay, Of Counsel

Signpost pointing in different directions

HMRC’s latest published statistics show continued growth in both the number of taxpayers holding cryptoassets and associated tax receipts, making cryptoasset holders an increasingly prominent target for HMRC.

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Thinking - Publication

Tax Bites - September 2026

Published on 02 September 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Daniel Williams, Associate

Man on the phone

Welcome to our September 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Thinking - Blog

Tribunal finds that film partnerships were carrying on a genuine trade

Published on 27 August 2026. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

Tax tribunal finds that film partnerships were carrying on a genuine trade and that the equity funded portion of their film production expenditure qualified for tax relief, but the debt-financed portion did not.

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Thinking - Publication

VAT update August 2026

Published on 26 August 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Jasprit Singh, Senior Associate

Asian woman outside holding pink shopping bags

Welcome to the August 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.

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Thinking - Publication

Customs and Excise quarterly update – August 2026

Published on 25 August 2026. By Michelle Sloane, Partner and Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime

Woman shopping check her phone

Welcome to the August 2026 edition of RPC's Customs and Excise quarterly update.

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Thinking - Blog

Full-time whistle blown in football referees employment status case

Published on 20 August 2026. By Daniel Williams, Associate

Signpost pointing in different directions

In Professional Game Match Officials Ltd v HMRC [2026] UKFTT 654 (TC), the First-tier Tribunal allowed the taxpayer's appeal and held that football referees' individual match engagements were contracts for services and not contracts of employment.

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Thinking - Podcast

Taxing Matters: Whistleblowing under the Strengthened Reward Scheme, with Adam Craggs

18 August 2026

Driving through a tunnel

In this episode of Taxing Matters, host Michelle Sloane is joined by RPC's Head of Tax, Investigations and Financial Crime, Adam Craggs to examine the merits and drawbacks of the Strengthened Reward Scheme (SRS).

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Thinking - Blog

Statutory Residence Test - Tribunal rejects HMRCs arguments

Published on 13 August 2026. By Jasprit Singh, Senior Associate

Signpost pointing in different directions

Tax Tribunal confirms that taxpayer was non-resident under the statutory residence test as three days fell within the transit exception and one day within the exceptional circumstances exception.

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Thinking - Blog

Court of Appeal confirms loan from EBT does not constitute taxable earnings

Published on 06 August 2026. By Daniel Williams, Associate

Signpost pointing in different directions

In HMRC v MR Currell Ltd [2026] EWCA Civ 445, the Court of Appeal upheld the decision of the Upper Tribunal and confirmed that a genuine loan, which was expected to be repaid, did not constitute taxable earnings under section 62, Income Tax (Earnings and Pensions) Act 2003 (ITEPA 2003). The case was distinguishable from RFC 2012 plc (in liquidation) (formerly The Rangers Football Club plc) v Advocate General for Scotland [2017] STC 155 (Rangers).

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Thinking - Publication

Tax Bites - August 2026

Published on 05 August 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Daniel Williams, Associate

Asian woman outside holding pink shopping bags

Welcome to our August 2026 edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.

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Thinking - Blog

Contentious Tax Quarterly Review – Summer 2026

Published on 30 July 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Liam McKay, Of Counsel

Signpost pointing in different directions

This Contentious Tax Review provides commentary on a number of recent important decisions in the tax disputes arena concerning: (1) HMRC's increasing use of strike out and the First-tier Tribunal's approach to such applications; (2) costs incurred as a result of HMRC's unreasonable conduct before an appeal is filed; and (3) the difficulties faced by taxpayers when pursuing applications for disclosure against HMRC.

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Thinking - Publication

Corporate tax update - May and June 2026

Published on 29 July 2026. By Ben Roberts, Partner and Julia Szerer, Associate (Qualified in Belgium)

Couple shoe shopping

Welcome to the latest edition of our Corporate Tax Update covering key developments from May and June 2026, written by members of RPC's tax team.

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Thinking - Publication

VAT update July 2026

Published on 29 July 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Jasprit Singh, Senior Associate

Woman shopping in supermarket

Welcome to the July 2026 edition of RPC's VAT update, your monthly source for news and analysis from the world of VAT.

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Thinking - Blog

New taxpayer duty to correct errors in tax returns

Published on 28 July 2026. By Adam Craggs, Partner, Head of Tax, Investigations & Financial Crime and Daniel Williams, Associate

Signpost pointing in different directions

On 13 July 2026, HMRC published draft legislation for inclusion in the Finance Bill 2027 which, if enacted, will introduce a new duty on taxpayers to correct errors identified in their tax returns.

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