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NEWS
Recent developments in tax.
Council adopts directive to boost tax cooperation
European council of the European Union has adopted a directive amending EU rules to strengthen administrative cooperation in taxation concerning the reporting and automatic exchange of information on revenues from transactions in crypto-assets and on...
UN Model tax treaty and impact of remote working
The United Nations’ tax sub-committee is considering revising Article 15 of the UN Model tax convention to address the reduction of the tax base in the country where an employer is based, when an employee is carrying out their duties in another...
Further Autumn Statement 2023 representations
The CIOT has submitted two more representations to the Treasury ahead of the 22 November 2023 Autumn Statement:Tax treatment of cryptoassets: the CIOT proposes that cryptoassets should be recognised and dealt with expressly in legislation across the...
Trust registration service brings clarity to beneficial ownership
New HMRC statistics show that the total number of new trust registrations in the 12 months to 31 March 2023 hit 462,000 – a substantial increase over the 33,000 registrations in the previous 12-month period. The dramatic increase reflects the 1...
Employer Bulletin: October 2023
HMRC’s latest roundup for employers covers the relaunched ‘fit note’, changes to HMRC’s interpretation of the tax treatment for home charging of electric company cars, and correcting payroll errors:HMRC’s Employment Income Manual has been updated (at...
HMRC manual changes: 13 October 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
HMRC targets ‘worst’ avoidance scheme
HMRC has issued Spotlight 63, highlighting an avoidance scheme marketed to landlords which claims to bypass the restrictions on mortgage interest relief, reduce taxable profits from the property business and reduce CGT and IHT.In very basic terms,...
Carried interest: HMRC dismisses GLP's claims
The Good Law Project (GLP) recently challenged HMRCs approach to the taxation of carried interest, contending that the regime has no basis in law and that the normal income tax rules should apply in most cases (rather than carried interest...
CIOT identifies potential pitfall in salary advance proposals
Responding to HMRC’s consultation on the delayed reporting of advance salary payments to employees, the CIOT agrees that the proposals would ease the administrative burden for employers by delaying the requirement to report the advance part of a...
HMRC issues self-assessment nudge letters
As part of its one to many ‘nudge letter’ approach to compliance, HMRC has started writing to agents whose clients’ tax returns for 2021/22 may have included ‘discrepancies’ when compared to other information held by HMRC. The potential errors relate...
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EDITOR'S PICK
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
1 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
2 /7
The new Securities Transfer Tax: business as usual?
Georgina West
3 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
4 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
5 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
6 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
7 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Perenco UK Ltd v HMRC
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?