Double tax treaties (DTTs) have a dual nature. They are: • international conventions between contracting states, and • part of the domestic law of a contracting state Accordingly, in order for a DTT to come into force each contracting state must: • sign and ratify the treaty, and • incorporate the provisions of the treaty into its domestic law In some jurisdictions, a DTT is automatically incorporated into domestic law as soon as it is signed and ratified. In other jurisdictions, such as the UK, a further legislative process is required. The arrangements specified in a DTT (and any amending protocol) are incorporated into UK domestic law as schedules to ‘Orders in Council’ and are published as statutory instruments (SIs). Once the DTT has taken effect in the domestic law of both the UK and its treaty partner, and any additional formalities or procedures specified in the DTT (such as exchanging diplomatic notes) have been completed, the DTT will come into force. The DTT will specify the date(s) on which it will have effect

This tracker displays the status and most recent developments of key tax cases in the UK Upper Tribunal (UT), the Upper Tribunal for Scotland, the England and Wales Court of Appeal (Court of Appeal), the Northern Ireland Court of Appeal, the Court of Session and the UK Supreme Court. The tracker also includes cases where an appellate court or tribunal has remitted the matter to a lower court or tribunal (typically, the First-tier Tax Tribunal (FTT)) for reconsideration. Finally, the tracker includes tax-related rulings by the Court of Justice of the European Union. The tracker is split into three parts: • active appeals, for cases where (1) one or more parties have applied for permission to appeal, (2) permission to appeal has been granted and appeal proceedings have commenced in the appellate court or tribunal, (3) the appellate court or tribunal has heard an appeal and a decision is awaited, or (4) an appellate court or tribunal has remitted a case to a lower court or tribunal for reconsideration • potential appeals, for cases where a court or tribunal has

This Practice Note is a consolidated version of the HMRC Manuals tracker that appears each week in the Tax weekly highlights, organised by HMRC Manual and in reverse chronological order going back to 1 January 2022. It covers many of the significant changes to the HMRC Manuals listed below that may be of key interest to Tax practitioners. It does not include changes to other authorities’ manuals covering devolved taxes. For HMRC Manuals tracking that is more tailored to Private Client practitioners, see Practice Notes: Consolidated HMRC Manuals tracker 2025–26–Private Client and Consolidated HMRC Manuals tracker 2021–24—Private Client [Archived]. Admin Law Manual Page(s) amended Date of change Comments Updated: ADML1300, ADML1400 1 September 2026 These pages cover public law principles governing when HMRC may be bound by incorrect advice under the doctrine of substantive legitimate expectation. HMRC has materially revised its treatment of detriment.Rather than stating that a customer can only establish detriment through real harm or loss, the guidance now recognises that detrimental reliance is not a prerequisite to bringing a successful substantive legitimate

This Tax tracker shows the current status of, and developments on, consultations (both formal and informal) conducted by the UK government (and other bodies) that have an impact on taxation and, where appropriate, the legislative outcome of those consultations. It also shows the current status of tax-related Bills before the UK Parliament, the Scottish Parliament, the Welsh Parliament and the Northern Ireland Assembly (other than Finance Bills, which are tracked separately). The tracker is split into five parts: • Tax-related Bills • Tax-related Acts • Open consultations—ie, consultations open for responses • Closed consultations—ie, consultations closed to new responses, and • Concluded consultations—ie, consultations closed to new responses and a summary or outcome has been published For information on OECD consultations that relate to the OECD's Base Erosion and Profit Shifting Action Plan, see: Tax—Base Erosion and Profit Shifting tracker. Tax-related Bills At present, there are no tax-related Bills before Parliament. Tax-related Acts The following table shows tax-related Acts that received Royal Assent in the previous 18 months, other than Finance Acts. For more information

This new starter guide provides an introduction to tax. It is aimed at trainee solicitors and those who are new to the area. It focuses on the key issues that arise in tax and includes links to sources and materials which provide more information on the topics covered. Those who are new to tax may also find useful the Overviews in each of the subtopics in the Lexis+® UK Tax Practical Guidance module. These Overviews give an introduction to each of the subtopics in the module with links to relevant content within the subtopic. This guide also contains links to help new starters make the most of the Lexis+® UK Tax Practical Guidance materials, including how to sign up for email alerts and contact the LexisAsk team. The role of a tax lawyer Tax lawyers are responsible for advising their clients on one or more areas of tax law. This typically requires them to monitor legislative and case law developments and advise their clients on how these changes will affect them. They may advise on the tax implications

Tax analysis: The government published Finance Bill 2026, also known as Finance (No 2) Bill 2024–26 and Finance Bill 2025–26 (FB 2026), on 4 December 2025.

The following Tax resources, providing useful practical commentary, legislation, rules and guidance for tax lawyers, whether in private practice or in-house, are available in Lexis+® UK. They are referenced and linked to in the Tax content in Lexis+® UK. Please note, however, the titles listed can only be accessed with the relevant Lexis+® UK subscription(s). Core business tax resources Title Summary Who should use this resource? Yellow Tax Handbook Provides the consolidated and annotated text of all legislation and official material relating to income tax, capital gains tax, corporation tax, National Insurance contributions (NICs), tax credits, petroleum revenue tax and inheritance tax, including references to Simon’s Taxes and HMRC Manuals, where relevant.  Lawyers and tax practitioners who wish to read the underlying legislation relating to direct taxes and want to carry out research into guidance around a particular section of direct tax legislation. Orange Tax Handbook Provides the consolidated and annotated text of all legislation and official material relating to VAT, stamp and transfer taxes, insurance premium tax, soft drinks industry levy, plastic packaging tax, landfill tax, aggregates

FORTHCOMING CHANGE: At Tax Update 2026, HMRC published a consultation on 'Modernising the distributions framework'. The consultation includes a range of proposals aimed at reducing opportunities for income tax payers to extract value from companies in the form of capital rather than income, including: • preventing the implementation of new holding company structures which facilitate the extraction of value as capital. Currently, the insertion of a new holding company above an existing group holding company results in the shareholders holding ‘good tax capital’ in the new holding company equal to the market value of the old holding company’s shares. A reduction in capital of the new holding company therefore represents a repayment of capital rather than an income distribution. The consultation proposes that share buybacks and other returns of capital ‘reflect a “frozen” amount of capital on the shares in any future holding company at the amount subscribed on the original investment, matching the CGT deferment of the original base cost’ • relaxing the tax conditions to effect a direct or indirect statutory demerger • aligning

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The Technology and Construction Solicitors' Association.

The Technology and Construction Solicitors’ Association (TeCSA) has published a revised version of its Adjudication Rules, updated other information relating to its adjudication service, and issued new guidance for adjudicators.

Law360: An employment tribunal (ET) has dismissed a teacher's claim that she lost her job after blowing the whistle during a feud over the handling of a child who wished to change gender.