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IN BRIEF
Views on recent developments in tax.
A statutory residence test bear-trap
David Whiscombe
It’s easy to be caught out by the second automatic UK test.
Protected income and offshore income gains
Peter Vaines
OIGs are not protected foreign income.
Excluded property trusts and 6 April 2025
Patrick Way
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.
IR35, staffing companies and the small company threshold
The increase in small company thresholds will take more contractors outside the scope of the off-payroll working rules.
Country-by-country reporting goes public
The advance of mandatory public country-by-country tax reporting is forcing large businesses to reconsider their approach to tax transparency.
When is 20% not 20%?
The real impact of the proposed changes to business property relief on trading companies.
Are multiple trusts still a viable IHT planning strategy?
Despite the recent APR/BPR consultation, multiple trusts still have their place.
Avoid shareholder debt write-offs in corporate transactions
Andrew Marr
An easy way to go wrong.
Update on the Register of Overseas Entities
Sam Epstein
Klara Kronbergs
The trust information protection provisions are now live, although some provisions won’t take effect until 31 August 2025.
Carried interest compliance
Ian Zeider
Tom Margesson
HMRC update their
Investment Funds Manual
(at IFM37800 and IFM37850).
Go to page
of
197
EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 25 April 2025
DST was always meant to be temporary, says Exchequer Secretary
HMRC change approach to CIR reporting
R&D relief: HMRC to update guidance on going concern rules and intra-group transfers
Pre-development costs consultation postponed
CASES
Read all
WTGIL Ltd v HMRC
Vaccine Research Limited Partnership and another v HMRC
George Mantides Ltd v HMRC
Refinitiv Ltd and others v HMRC
Other cases that caught our eye: 25 April 2025
IN BRIEF
Read all
A statutory residence test bear-trap
Protected income and offshore income gains
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: The new FIG regime: who are the real winners?
Loan Charge review: call for evidence