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IN BRIEF

Views on recent developments in tax.

It’s easy to be caught out by the second automatic UK test.
OIGs are not protected foreign income.
A quarter period for inheritance tax may last for only a day or so on or after 6 April 2025 when excluded property trusts may become relevant property trusts. So move fast.
The increase in small company thresholds will take more contractors outside the scope of the off-payroll working rules.
The advance of mandatory public country-by-country tax reporting is forcing large businesses to reconsider their approach to tax transparency.
The real impact of the proposed changes to business property relief on trading companies.
Despite the recent APR/BPR consultation, multiple trusts still have their place.
The trust information protection provisions are now live, although some provisions won’t take effect until 31 August 2025.
HMRC update their Investment Funds Manual (at IFM37800 and IFM37850).
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