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NEWS
Recent developments in tax.
HMRC reminder of duty to notify
In its stakeholder digest (31 August 2023), HMRC reminds taxpayers of the duty to notify a liability to income tax or capital gains tax for the tax year 2022/23 by 5 October 2023 (i.e. by six months after the end of the tax year). HMRC asks readers...
New customs rules for Northern Ireland
The Customs (Northern Ireland) (EU Exit) (Amendment) Regulations, SI 2023/958 update the UK customs duty rules for goods which are moved between Great Britain and Northern Ireland, based on a new wider definition of whether goods are at...
Half of R&D claims ‘non-compliant’
In a formal reply to the CIOT’s 3 July 2023 letter which raised various challenges around HMRC’s compliance approach to R&D claims, HMRC has committed to improving the quality of its handling of claims. HMRC understands, however, that half of all...
SAYE and SIPs under review
The SAYE and SIP employee share schemes broadly achieve their objectives, but simplification of the rules and making sure wider groups of employees can access the schemes are the way forward, says the CIOT. The CIOT was responding to the Treasury...
HMRC consults on insurance company ‘structural assets’
HMRC is consulting until 26 September 2023 on draft regulations which will set out which assets of a company’s long-term insurance business are ‘structural assets’. The broad definition of structural assets for this purpose is set out in FA 2012 s...
CIOT responds to Amount B consultation
The CIOT has responded to the OECD consultation Pillar One: Amount B on simplifying the transfer pricing of baseline marketing and distribution activities in accordance with the arm’s length principle. Key points include:Transactions within the scope...
HMRC focusing on transfer pricing
HMRC collected some 70m in extra tax in the financial year to 31 March 2023 through voluntary disclosures by MNEs via its Profit Diversion Compliance Facility, reports Pinsent Masons. The facility allows businesses to voluntarily disclosure...
HMRC manual changes: 1 September 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
EC adopts reporting rules for CBAM’s transitional phase
The European Commission has adopted the rules governing the implementation of the carbon border adjustment mechanism (CBAM) during its transitional phase which starts on 1 October and finishes at the end of 2025. These cover the transitional...
Bermuda consults on a new corporate income tax
Bermuda is consulting until 8 September 2023 on proposals to introduce a corporate income tax which would apply to Bermuda businesses that are part of MNEs with an annual revenue of 750m. This is the first of a planned series of consultations...
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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
Knights Developments Ltd v HMRC
Perenco UK Ltd v HMRC
Consultation tracker