The latest edition of Slaughter and May's Tax News podcast (July 2026) is out now, hosted by Zoe Andrews (Head of Tax Knowledge) and Tax associate Amy Motherwell.

The podcast covers several developments that may be relevant to you including:

• Key cases: The Supreme Court's decision in HFFX on the limits of purposive construction and the charge to miscellaneous income; the Upper Tribunal's decision in Barclays Services Corporation upholding the FTT's finding that a US company's UK branch lacked sufficient resources to constitute a fixed establishment for VAT grouping purposes; and the Upper Tribunal's decision in Swiss Centre on when payments qualify for deductions under the loan relationship regime.
• UK developments: HMRC's consultation on reducing the high effective tax rates faced by UK-resident individual members of US LLCs and other reverse hybrid entities; the surprise consultation on modernising the distributions framework covering share buybacks, demergers, returns of capital and transactions in securities; and HMRC's Transformation Roadmap progress update including new third-party data reporting obligations and plans to improve digital services.
• International spotlight: The European Commission's tax simplification package comprising a Direct Taxation Omnibus Directive amending six existing EU tax directives and a DAC recast consolidating all administrative cooperation rules into a single instrument — with adoption of the DAC recast potentially achievable by end of 2026.

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

• Supreme Court's Gunfleet Sands decision: A restrictive ruling on capital allowances for predevelopment costs
• Electricity Generator Levy: Increase from 45% to 55% from July 2026, with voluntary fixed-price contracts
• Court of Appeal in Burlington : Important clarification of treaty purpose tests, with global implications for the principal purpose test
• Court of Appeal in MR Currell : The purpose of a payment does not determine its legal character
• VAT classification of Mega Marshmallows (Innovative Bites ): They're zero-rated food, not confectionery
• Inbound redomiciliation consultation: Proposals to allow foreign companies to move their place of incorporation to the UK

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.