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IN BRIEF

Views on recent developments in tax.

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).

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.

Insight from the Upper Tribunal on a ‘debt incurred’.
We now have a clearer picture, although there’s still some way to go and one notable omission.
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