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Recent developments in tax.
New Advance Tax Certainty Manual
On 1 June 2026, HMRC published a new Advance Tax Certainty Service Manual containing guidance on which customers are eligible for the new service, the scope of taxes for which advance tax certainty can be provided, and situations where HMRC will not...
HMRC relax ERS reporting for short-term business visitors
HMRC have confirmed a relaxation of employment-related securities (ERS) reporting requirements for certain short-term business visitors (STBVs). In Employment Related Securities Bulletin 66 for May 2026, HMRC state that, for non-tax advantaged share...
HMRC update SP 1/2001
HMRC have updated Statement of Practice 1/2001 on the treatment of investment managers and their overseas clients, reflecting FA 2026 changes to the Permanent Establishment rules and Investment Manager Exemption (IME). The revised statement,...
VAT Notice 742A clarification
HMRC have updated VAT Notice 742A, with the main change at section 12.1 to clarify that, where opted land or buildings remain an asset on hand at the point of VAT registration cancellation, output tax must be accounted for. This also means that,...
OECD consults on TP guidelines
The OECD has opened a public consultation on proposed revisions to Chapter VII of its Transfer Pricing Guidelines, covering special considerations for intra-group services. The OECD reports that the revisions are not intended to change the general...
Procedure for resolving privileged information disputes
The Anti-avoidance Information Notices (Resolution of Disputes as to Privilege) Regulations, SI 2026/560, set out the procedure for resolving disputes on whether information requested in an HMRC anti-avoidance information notice is subject to legal...
Multi-factor authentication guide
The CIOT and ATT have released a joint guide, Multi-Factor Authentication – how can agents prepare?, outlining the steps tax agents must take to secure their HMRC Agent Services Accounts (ASA) and legacy Online Services Accounts (OSAs) against...
Tax KC faces cheating charges
Tax barrister Robert Venables KC is on trial at Southwark Crown Court charged with three counts of cheating the public revenue. The prosecution allege that, between 2014/15 and 2020/21, Venables under-declared income from his legal practice,...
Tax Journal authors for May
Tax Journal thanks its authors for May (click on links below to view author profiles and access their contributions):Karen Bannister and Gary Barnett - The VAT review for MayHenry Bennett-Gough and Amelia Roffey - Employment status in regulated...
Foreign Permanent Establishment exemption to be made mandatory
The government has announced plans to make the foreign Permanent Establishment (PE) exemption mandatory for UK-resident companies from 2027, in a move aimed at preventing multinational groups from using foreign branch losses to reduce UK corporation...
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EDITOR'S PICK
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
1 /7
Spare us the cUTTer
Nick Thornton
2 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
3 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
4 /7
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
5 /7
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
6 /7
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
7 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
Burlington: towards an international fiscal meaning of ‘main purpose’
Kyle Rainsford
Is a loan earnings? Revisiting Rangers
Dominic Stuttaford
,
Katharine Wadia
Qualifying Asset Holding Companies: don’t let your ‘kwæk’ end up in the ‘kæk’
Nick Thornton
NEWS
Read all
Professional bodies warn against UTT expansion
Close company reporting: ‘benefits lost in a sea of data’
HMRC clarify CIS treatment of pure financing arrangements
HMRC guidance gives comfort on management rollovers
Further compensation payments exemption
CASES
Read all
Lifeplus Europe Ltd v HMRC
MyPay Ltd v HMRC
WWM (Harrogate) LLP v HMRC
Other cases that caught our eye: 12 June 2026
Bagshaw Ltd v Revenue Scotland
IN BRIEF
Read all
Information notices
Management rollovers and share-for-share exchange relief
Krason: careless conduct
IHT replacement property relief restrictions
HMRC clarify CIS financing positions
MOST READ
Read all
HMRC clarify CIS financing positions
Ask an expert: Dividend planning under the new close company reporting regime
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Consultation tracker
One minute with… Jon Claypole