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NEWS
Recent developments in tax.
LBTT relief for Scottish green freeport tax sites
The Land and Buildings Transaction Tax (Green Freeports Relief) (Scotland) Order, SSI 2023/280, inserts new Sch 16D into the Land and Buildings Transaction Tax (Scotland) Act 2013 to provide for relief from LBTT for eligible transactions within a...
New agreement on global minimum tax
The OECD/G20 Inclusive Framework on BEPS has concluded negotiations on a new multilateral instrument that will protect the right of developing countries to ensure multinational enterprises pay a minimum level of tax on a broad range of cross-border...
Draft legislation for undertaxed profits rule updated
The ‘Legislation Day’ July 2023 draft legislation setting out the multinational top-up tax undertaxed profits rules has been amended to include safe harbours and other features of the OECD’s latest administrative guidance. The main amendments to the...
New remittance basis toolkit for agents
HMRC has published a new toolkit, Assurance of Remittances of Foreign Income and Gains Toolkit, to help agents decide whether remittance-basis clients have remitted taxable income to the UK. HMRC says that ‘the toolkit is not technical guidance about...
BEPS MLI: Eswatini, Armenia, Côte d'Ivoire and Serbia
Eswatini has signed up to the BEPS Multilateral Instrument, bringing the number of jurisdictions which have ratified, accepted or approved the Convention to 101.Armenia and Côte d'Ivoire have deposited their instruments of ratification for the BEPS...
CIOT recommends a number of safeguards on EOTs and EBTs
Noting that many of the recommendations from its 2021 submission have been included in HMRC’s recent consultation: Taxation of Employee Ownership Trusts and Employee Benefit Trusts, the CIOT makes a number of further points:EOTs:preventing former...
New UT electronic filing directions
The senior president of tribunals has issued a new practice direction for the electronic filing of documents for proceedings before the Tax and Chancery Chamber of the Upper Tribunal which begin on or after 2 November 2023.Where a party to...
HMRC putting the boot in on UK football
Tax investigations into UK football clubs have brought in some £125m of tax in the year to 31 March 2023, up from £59m in the previous year, reports UHY Hacker Young. According to the firm, HMRC has been looking particularly at NICs on agents’ fees,...
Tax Journal's authors for September 2023
Tax Journal thanks its authors for September 2023. Click on links below to view author profiles.
HMRC manual changes: 29 September 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
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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?