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NEWS
Recent developments in tax.
HMRC manual changes: 21 November 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Tax stability key for internationally mobile individuals
A new survey suggests that tax policy stability is a higher priority than tax rates, for internationally mobile wealthy individuals. Figures from BDO’s September 2025 poll of 200 wealthy individuals reveal that stability of government, simplicity of...
HMRC campaign on management expenses
HMRC have launched a one-to-many letter campaign aimed at large businesses on the claiming of management expenses under CTA 2009 s 1219, the CIOT confirms. The initial intention behind the letters to businesses and agents is to give advance notice...
Partnership NICs potentially scrapped, but concerns remain
Although rumoured to have been dropped by the Chancellor, partnership NICs could impose a charge on income not received by partners (given the common practice of leaving money in the firm) and cause resulting damage to the professional services...
Set tax thresholds at real values, says IFS
Extending the freeze in income tax thresholds by a further two years, as reportedly being considered by the Chancellor, would raise significant extra tax for the Exchequer in a ‘broad-based and progressive way’, says a recent report by the Institute...
Public services pension remedy: offsetting of tax charges
HMRC have published new guidance for administrators of public service pension schemes on the process for offsetting refunds of tax charges against charges arising in respect of members who receive top-up lump sums under the public services pension...
UK extends Gibraltar financial services arrangements
The Financial Services (Gibraltar) (Amendment) (EU Exit) Regulations, SI2025/1182, extend by a further 12 months (until 31 December 2026), the transitional arrangements which allow certain categories of Gibraltar-based financial services firms to...
OECD Model Tax Convention updated
The OECD has issued an update to its Model Tax Convention. The 2025 update introduces changes approved on 18 November 2025 which will be incorporated in revised, condensed and full editions of the Model, scheduled for publication in 2026. The update...
GenAI ‘top priority’ say tax leaders
Harnessing the power of generative AI and technology, alongside managing Pillar Two obligations and aligning tax insights with their overall organisational strategy, are three key priorities for businesses, reveals EY’s 2025 Tax and Finance...
HMRC manual changes: 14 November 2025
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
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
1 /7
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
2 /7
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
3 /7
Mandatory agent registration: what we know so far
Jane Mellor
4 /7
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
5 /7
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
6 /7
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
7 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
Hotel La Tour: where next for input tax recovery on share disposals?
Rupert Shiers
,
Laura Hodgson
Mandatory agent registration: what we know so far
Jane Mellor
Permanent Establishment reform: what has changed, who is affected and why does it matter?
Rob Sharpe
,
Iarlaith McCarthy-Hann
The Pillar Two Side-by-Side package: how UK groups should approach compliance
Jack Gifford
Share reorganisations: new anti-avoidance rules explained
Peter Morley
,
Jamie Robson
NEWS
Read all
Tax Journal authors for March
New reporting requirements for close company payments proposed
Lords amendments to NICs Bill rejected
Call for evidence: phase out of remaining ACT regime
Call for evidence: business systems integration
CASES
Read all
HMRC v C Brzezicki
J Hosking v HMRC
L Rowland & Co (Retail) Ltd v HMRC
Other cases that caught our eye: 27 March 2026
Muller UK and Ireland Group LLP and others v HMRC
IN BRIEF
Read all
Exceptional circumstances – but which way?
Tax agent registration and financial services
Provisions
New SDLT burden for private renters
Transactions in Securities counteraction notices
MOST READ
Read all
J Hosking v HMRC
Exceptional circumstances – but which way?
Countrywide Partners Ltd v HMRC
Muller UK and Ireland Group LLP and others v HMRC
Consultation tracker