IN BRIEF

Views on recent developments in tax.

The long-awaited IHT consultation on the proposed reforms to agricultural and business property relief (APR and BPR) (coming in from 6 April 2026) emerged yesterday afternoon (27 February 2025). The consultation is open for two months. Although the consultation was largely as expected, there were a few clarifications and new details which Sarrah Way (Charles Russell Speechlys) discusses here.

Shanzé Shah

Insight from the Upper Tribunal on a ‘debt incurred’.

Benjamin Craig

We now have a clearer picture, although there’s still some way to go and one notable omission.

Helen McGhee

Lynnette Bober

The latest Finance Bill amendments correct some technical errors and include a few helpful changes to the Temporary Repatriation Relief.

David Whiscombe

The Court of Appeal judgment in A Taxpayer might not be quite the gift for taxpayers that it first appears to be.

Does the dissent in the recent Supreme Court case of Royal Bank of Canada signal changes to statutory construction principles?

Chris Mortimer

VAT compliance ‘nudge letters’ from HMRC target private equity firms.

Philip Ridgway

... and the problematic quasi-legislative nature of HMRC’s guidance.

Elena Rowlands Ian Zeider Tom Margesson

HMRC are to reverse their controversial guidance changes on increases in capital contributions.

Helen Buchanan

From challenging the tax treatment of partnerships to taking a less collaborative approach on audits, HMRC appear to be taking a tougher approach on a host of corporate tax issues.

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