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NEWS
Recent developments in tax.
Small profits rate not available for non-resident companies
The CIOT has issued a technical update clarifying that non-UK resident companies subject to UK corporation tax cannot claim the small profits rate or marginal relief. Under CTA 2010 s 18A, the rate applies only to UK-resident companies. While there...
HMRC appoint R&D expert advisory panel
HMRC have appointed a new R&D advisory panel, to enhance the department’s expertise and understanding in relation to claims for R&D tax relief. The six independent industry specialists will bring ‘real world experience, offering deep sectoral...
Special tax sites designated in Wales
The following regulations designate further special tax sites, in which the usual tax reliefs apply, in the Anglesey Freeport and the Flintshire and Wrexham Investment Zone, with effect from 21 November 2025:Designation of Special Tax Sites (Anglesey...
CIOT on tax barriers to housing supply
The CIOT has made a written submission on the tax barriers to housing supply, which includes detailed discussion of the CGT, SDLT and VAT issues arising from neighbouring land owners acting together to secure a land sale. ‘Tax Barriers to Housing...
Repayment interest and commercial restitution for VAT
In a Budget representation on repayment interest and commercial restitution for VAT, the CIOT sets out its rationale for the need to review repayment interest and address the inequity brought about by the late-payment interest regime as it applies to...
Italy plans to raise flat tax for wealthy new residents by 50%
In its draft 2026 Budget plans, the Italian Government is proposing to raise the annual flat tax for new wealthy residents from €200,000 to €300,000 from 2026. The measure targets those relocating to Italy and paying the fixed tax on foreign income,...
EU publishes updated list of noncooperative jurisdictions
The EU has updated the EU list of non-cooperative tax jurisdictions. Annex I remains unchanged, currently comprising 11 jurisdictions. Vietnam has been removed from Annex II after successfully implementing the OECD’s BEPS minimum standard on...
New UK-Portugal DTC signed
The UK and Portugal have agreed a new Double Taxation Convention, replacing the previous 1968 agreement between the two countries. Although the Convention was signed in September 2025, it will not enter into force until the completion of all...
Updated list of Pillar Two territories and taxes
HMRC have updated ‘Notice 2: Pillar Two top-up taxes relevant territories and taxes’, adding to the lists of territories which have implemented Pillar Two rules and are specified for the purposes of Multinational Top-up Tax and Domestic Top-up...
Reintroduce certificates of tax deposit, says CIOT
In a Budget representation, the CIOT calls for the Treasury to reintroduce certificates of tax deposit (CTDs). The scheme closed for new purchases on 23 November 2017, although HMRC continued to honour existing certificates until 23 November...
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
HMRC manual changes: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC