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NEWS
Recent developments in tax.
Draft multinational top-up tax guidance
The CIOT has responded to HMRC’s consultation on draft guidance destined for a new internal guidance manual on the multinational top-up tax (MTT) and domestic top-up tax (DTT) which were introduced in Finance (No 2) Act 2023. Key observations...
CIOT responds to Draft Finance Bill clauses
The CIOT has responded to the general consultation on the following proposals which were included in the July 2023 ‘Legislation Day’ Finance Bill drafts:Single, merged scheme for R&D, and additional relief for R&D-intensive SMEs: implementation of...
Economic crime levy: interest
The Finance Act 2009, Sections 101 and 102 (Economic Crime (Anti-Money Laundering) Levy) (Appointed Day) Order, SI 2023/997 appoints 30 September 2023 as the date on which the FA 2009 ss 101 and 102 interest provisions come into force for the...
HMRC publishes guidance on approach to tax disputes
HMRC has published new guidance on its internal procedures for deciding how tax disputes should be resolved, depending on the particular circumstances of a dispute and how much tax is at stake:Code of Governance for Resolving Tax Disputes: this...
HMRC manual changes: 15 September 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Proposed data-gathering provisions too wide, says ATT
In its response to the general consultation on draft clauses for the next Finance Bill, the ATT has highlighted a significant gap between the policy intention and the wording of the legislation. The draft Finance Bill legislation gives HMRC extended...
HMRC launches overlap profits request form
As had been anticipated, HMRC has now launched its new online form which taxpayers affected by the move to the tax year basis can use to request details of overlap profits held by HMRC. Overlap relief can be used to set off extra profits brought into...
CIOT responds to umbrella company market proposals
HMRC’s wide-ranging consultation Tackling non-compliance in the umbrella company market, (covering both tax and employment rights), looked at options to regulate umbrella companies, with one principal aim being to deal with tax non-compliance in the...
Tonnage tax training requirement regs
The Tonnage Tax (Training Requirement) (Amendment etc) Regulations, SI 2023/983, increase the amounts to be used in calculating payments in lieu of training, where operators are not able to meet the minimum training obligation.The amount payable each...
Public service pension schemes remedy regs
Two new sets of Regulations will enable affected individuals to choose how the public service pensions remedy will apply to them.The Public Service (Civil Servants and Others) Pensions (Remediable Service) Regulations, SI 2023/942, provide for...
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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?