The Supreme Court’s conclusion on the construction of CAA 2001 s 298 is key to how all other taxpayers with Enterprise Zone allowances appeals will now proceed, write Steven Porter and Sam Wardleworth (Pinsent Masons).
Supreme Court denies enterprise zone allowances.
R&D claim succeeds before FTT.
UT denies SDLT group relief because of tax avoidance main purpose.
Taxpayer loses right to confidentiality.
How do you value an APA after the Court of Appeal’s decision in Refinitiv?
The CIOT has responded to the draft legislation published at Autumn Budget 2024 which, when enacted, will make changes to the tax regime for employee-ownership trusts (EOTs) with effect from 30 October 2024. The EOTs provisions are set out in Sch 6...
FTT holds discrimination settlement payment not taxable.
May Smith and Emily Szasz (Freshfields) examine some of the key tax considerations that arise in relation to the transfer of assets into a continuation fund....
Recent cases suggest a worrying trend towards HMRC adopting a more combative approach to judicial review proceedings, write Robert Waterson and Rebekka Sandwell (Eversheds Sutherland).
The changes to the taxation treatment of LLPs upon liquidation are symptomatic of an increasing focus on the taxation of LLPs, write Gideon Sanitt and Victoria Braid (Macfarlanes).
This 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.
Film tax relief: In C Hoyle and others v HMRC [2024] UKFTT 1060 (TC) (26 November), the taxpayers took part in film tax schemes under which they invested in LLPs which leased film rights. Their investments were largely funded by loans and the...
Finance Bill 2025 received its Second Reading in the House of Commons on 27 November (meaning it passes to the Committee stages).A Committee of the Whole House (i.e. the House of Commons) will debate the following provisions on 10 and 11 December...
The OECD has published the following new reports on tax transparency and the automatic exchange of information, summarising the work of the Global Forum in recent years:15 Years: Promoting Transparency and Cooperation – a new report on 15 years of...
HMRC have issued the latest quarterly update to the company car advisory fuel rates, for journeys on and after 1 December 2024. Rates for all petrol and diesel car bands have been reduced by one penny. Employers may therefore decide to continue to...
Jonathan Legg (Mishcon de Reya) considers some of the latest issues – and some of the oldest – in the build-to-rent and purpose-built student sectors, focusing on SDLT and VAT.
The European Commission has closed three state aid investigations into transfer pricing tax rulings granted by Luxembourg to Fiat and Amazon, and by the Netherlands to Starbucks.The Commission has adopted final decisions, closing its investigations...
John Shallcross (Blake Morgan) sets out what can be learnt from a recent decision where the FTT held HMRC could refuse to give effect to an overpayment relief claim for SDLT involving MDR for mixed property.
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
HMRC have issued new guidance on paying UK Pillar Two top-up taxes (aimed at multinational companies within the UK’s multinational or domestic top-up taxes rules). The guidance covers payment deadlines and details required in order to make payments....
Shayaan Zaraq Bari and Nicholas Gardner (Ashurst) explain how combining W&I insurance with other tools may help bridge any gaps in tax risk coverage and maximise protection for buyers....
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
The changes to the pension investment sector are taking shape, but key tax policy questions remain unanswered.
The Land Transaction Tax (Relief for Special Tax Sites) (Wales) Regulations, SI 2024/1193, provide for relief from the Welsh land transaction tax for qualifying transactions of land in designated special tax sites in Wales – broadly mirroring the...
One minute with Anthony Newgrosh, Partner at BKL.
In this month’s review, Gary Barnett (Simmons & Simmons) reviews the agreement on ViDA, the consultation responses on CBAM in the UK and the impact of an Upper Tribunal decision on supplies by public bodies....
The Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024 received royal assent on 12 November 2024. The Act introduces the new Scottish aggregates tax which is expected to replace aggregates levy in Scotland from 1 April 2026.Part 1...
The UK is likely to become more attractive in the short term for overseas employees but less attractive in the medium to long term, Claire Murray and Nisus Larsen (Alvarez & Marsal) explain....
Latest case hearing dates and appeals.
The Exchequer Secretary to the Treasury, James Murray MP, said he decided to commit to the timeframe for Making Tax Digital for Income Tax Self-Assessment following ‘robust’ conversations with HMRC in the summer. He also said he took on...
A prime time ‘fact check’ analysis.
The proposed IHT reforms seem to attack the farmers they should protect and protect the people they should tax, writes Stuart Maggs (Howes Percival)....
HMRC’s Employment Related Securities Bulletin 58 outlines the proposed new PISCES trading platform, and includes several reminders of recent and forthcoming changes that will impact on employment-related securities:Private Intermittent Securities and...
Commenting on the Budget proposals to cap agricultural and business property reliefs and the well- publicised debate around the potential affects on the farming industry, the Institute for Fiscal Studies suggests that, if IHT is to exist, it should...
HMRC have published guidance on Making Tax Digital for Income Tax Self-Assessment (MTD for ITSA) covering how to catch up with digital records and submit quarterly updates during the tax year.HMRC remind those who have signed up to the testing phase...
Tax Journal thanks its authors for November (click on links below to view author profiles and access their contributions):Jo Bateson - Reflections on a career in taxAdam Craggs and Liam McKay - Alternative dispute...
The tax policies of President-elect Trump and the new European Commission are among the recent developments reviewed by Tim Sarson (KPMG).
Consultations, case hearings, and HMRC activity.
A broadly based wealth tax could replace the three capricious ones we have already.
HMRC’s Stakeholder Digest (29 November 2024) provides a number of reminders:voluntary NICs deadline, for making up contribution record gaps from 6 April 2006, is 5 April 2025. After that, the usual rules will apply allowing retrospective...
HMRC are attempting to make clear that, although new reporting requirements apply for online platform operators from January 2025, the tax position for individuals who sell items (or services) on those platforms remains unchanged. This appears to...
Jenny Doak and Akash Mehta (Weil, Gotshal & Manges) discuss some key considerations for M&A transactions....
The CIOT has written to the Treasury Committee, outlining thoughts and concerns on key tax measures announced at Autumn Budget 2024. The following points may be of particular interest for practitioners:NICs: the increase in employer contributions...
HMRC have updated the following guidance:Moving goods between Great Britain and the UK Continental Shelf: the form to report UK Continental Shelf imports and exports has now been added. The new form was introduced on 28 November 2024 to simplify the...
EU VAT changes mean double tax for UK livestream events.
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