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Recent developments in tax.
Amount A of Pillar One consultation
Thepublic consultation meetingon the progress report on Amount A of Pillar One held on 12 September focused on the marketing and distribution safe harbour (MDSH) and the elimination of double taxation. The OECD recognised the importance...
Compatibility of UK intra-group transfer rules with EU law
Advocate General (AG) Rantos has opined in Gallaher Ltd v HMRC (Case C‑707/20) that an imposition of an immediate tax charge on asset transfers outside the UK tax net is compatible with EU law.This request for a preliminary ruling from the Upper...
Offshore tax non-compliance
HMRC has published additional guidance on the requirement to correct offshore tax non-compliance. This additional guidance supplements the original guidance which was published back in November 2017. The original deadline for the requirement to...
Customs guidance roundup: 16 September 2022
HMRC has published further new and updated guidance for imports, exports, and customs to reflect the post-transition period regime: Correction for late payment interest on customs debt and £25 minimum charge: HMRC has published new guidance on how to...
Tax agent and adviser guidance
HMRC has published several guidance pages relating to HMRC online services for agents as follows:How to use the Online Agent Authorisation to get authorised as a tax agent (see bit.ly/onlineagentuse)How to get an agent reference number for PAYE (see...
UK/Germany tax treaty
HMRC has published the consolidated text of the 2010 UK/Germany Double Taxation Convention as amended by the 2021 protocol. The protocol took effect in the UK as follows:from 1 January 2022 for taxes withheld at source;from 1 April 2022 for...
Brazil/UK joint declaration
After exploratory talks to find common ground on the principles for a possible double taxation agreement, the UK and Brazil have announced the first round of negotiations, which will be launched during a visit by HMRC to Brasilia between 12 and 16...
Review of treaty policy positions
The CIOT has responded to the HMRC informal consultation on review of treaty policy positions in relation to changes to the article 5 of the OECD Model Tax Convention (MTC) as a result of the BEPS action reports and to the permanent establishment...
VAT appeals
HMRC has updated the list of VAT appeals that HMRC has lost and that may have implications for other businesses. See bit.ly/VATappealsSep....
Two new Scottish taxes
Two new Scottish taxes, the local visitor levy and the Scottish aggregates levy, have been announced by the Scottish government in its programme for government 2022/23, published on 6 September 2022.Also known as the tourist tax, the local visitor...
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EDITOR'S PICK
Tax Journal's 2025 Budget coverage
1 /7
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
2 /7
Medpro: better late than never
Stacey Cranmore
3 /7
No escape: the new IHT tax rules for pensions
Harriet Betteridge
4 /7
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
5 /7
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
,
Elvira Colomer Fatjo
6 /7
Understanding the FIG regime
Jo Bateson
7 /7
Tax Journal's 2025 Budget coverage
Management expenses: HMRC’s new nudge campaign
Anna Lucey
,
Constantine Christofi
Medpro: better late than never
Stacey Cranmore
No escape: the new IHT tax rules for pensions
Harriet Betteridge
What time is it? A review of the Supreme Court’s decision in Prudential
David Jamieson
The trials and tribulations of interest withholding tax
Bezhan Salehy
,
Rebecca Rose
Understanding the FIG regime
Jo Bateson
NEWS
Read all
Tax Journal authors for January
HMRC manual changes: 30 January 2026
Tax bodies back Lords concerns over IHT reforms, including ‘huge’ burden on PRs
Finance Bill 2026 amendments
PAYE changes for employment expenses and gift aid relief
CASES
Read all
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
Nimbus: The Disability Consultancy Service Ltd v HMRC
Delphi Derivatives Ltd (in liquidation) v HMRC
Other cases that caught our eye: 30 January 2026
HMRC v MedPro Healthcare
IN BRIEF
Read all
Concerns over the scope of new conduct rules for advisers
Revenue fraud
The new share for share anti-avoidance
Value on death: IHT
TSI Instruments and import VAT recovery
MOST READ
Read all
COP 9 and serious tax fraud: HMRC’s tougher approach
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
One minute with... Dilpreet K Dhanoa
Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
One minute with... Hayley Ives