April 13th, 2026
INTRODUCTION In the first part of this article on the catchy new “Prohibition against unregistered tax advisers interacting with HMRC”, we looked at: Why these provisions have been introduced; What these rules are and how they will be implemented When they will be introduced The ‘so what?’ Who the rules apply to In Part Two, […]
April 13th, 2026
WARM UP ACT As is obvious from the title, this article considers the new “Prohibition against unregistered tax advisers interacting with HMRC”. What? It wasn’t obvious? Ok, well, from 18 May 2026, if you’re paid and you interact with HMRC about someone else’s tax affairs, your legal entity needs to register unless an exemption applies. […]
March 21st, 2026
Introduction The coverage of this month’s vintage‑guitar “gold rush” is a reminder that ‘passion’ assets don’t just capture hearts… Yes, I am talking about the sale of Jim Irsay’s amazing collection of guitars. Irsay was an American billionaire businessman who died last year. He was the principal owner, chairman, and CEO of the Indianapolis Colts of the National Football […]
March 19th, 2026
PART THREE: HOW THE JSL PROVISIONS AFFECT SPECIFIC ENTITIES INTRODUCTION If Part Two examined the point of impact, Part Three looks at what happens in the aftermath. The statutory framework is one thing… how it applies across real-world structures is quite another. In practice, the new JSL rules do not land evenly. Instead, their effect […]
March 19th, 2026
PART TWO: THE FINANCE BILL THROUGH TO FINANCE ACT INTRODUCTION If Part One mapped the trajectory of the incoming rules, Part Two is where we examine the point of impact. The draft legislation, introduced in Finance Bill 2025/26 and now enacted in Finance Act 2026, sets out in precise terms how liability is reallocated across […]
