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NEWS
Recent developments in tax.
New guidance on Pillar Two GloBE Rules
The Inclusive Framework has published Agreed administrative guidance for the Pillar Two GloBE rules. The new guidance addresses various issues identified by Inclusive Framework members as most in need of immediate clarification and simplification.The...
OECD releases manual on Multilateral MAPs and APAs
The OECD has published a new Manual on the handling of multilateral mutual agreement procedures and advance pricing arrangements (MoMA). The manual is intended as a guide to multilateral MAP and APA processes from both a legal and procedural...
New MDR guidance published
HMRC has published new guidance in advance of the introduction, on 28 March 2023, of the requirement for taxpayers, promoters and advisers to disclose details of offshore avoidance arrangements under the mandatory disclosure rules (MDR). The...
New HMRC alternative dispute resolution guidance manual
HMRC has published a new Alternative Dispute Resolution Guidance Manual setting out how the ADR process is intended to work in practice, and including sections on the basic ‘ground rules’ for ADR and formal conclusions of ADR discussions....
CIOT Budget representations on employee expenses and repayment interest
The CIOT has submitted further sets of representations, ahead of the Spring 2023 Budget:1. Employment taxes and pensions: many of the CIOT’s recommendations address inconsistency around the tax treatment of expenses incurred by employees, with a...
HMRC raises interest rates again
HMRC is increasing the late payment rate of interest to 6.5%, and the repayment interest rate to 3% from 21 February 2023. Interest charged on underpaid quarterly instalments of corporation tax is increased to 5%, and interest paid on overpaid...
January 2023 authors
Tax Journal thanks its authors for January 2023 (click on links below to view author profiles).
HMRC manual changes: 3 February 2023
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Lords calls for R&D advance notifications to be dropped
In a new report Research and development tax relief and expenditure credit, the House of Lords Finance Bill Sub-Committee urges the UK government to abandon its proposed requirement for companies to make an advance notification of RD tax relief...
VAT threshold putting a brake on business
New data suggests that thousands of UK businesses are holding back growth to make sure they avoid hitting the VAT registration threshold. The data from 201819 shows a cliff-edge drop in the number of businesses by turnover band, as turnover...
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1115
EDITOR'S PICK
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
1 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
2 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
3 /7
The new Securities Transfer Tax: business as usual?
Georgina West
4 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
5 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
6 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
7 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
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
NEWS
Read all
Government’s consultation reset raises questions for tax policymaking
HMRC restate VAT position on supplies of education services
Scottish ADT provisions brought into force
OECD schedules public meeting on intra-group service guidance
HMRC issue new loan charge settlement scheme guidance
CASES
Read all
The Executors of Hunt and others v HMRC
Grand Smile Design Ltd v HMRC
S Knight v HMRC
Oakwood Great Oak Ltd v HMRC
Other cases that caught our eye: 11 September 2026
IN BRIEF
Read all
HMRC get more bang for their buck
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
MOST READ
Read all
Knights Developments Ltd v HMRC
The 2026 loan charge settlement scheme: the beginning of the end?
Consultation tracker
Prize draws and VAT: a lottery?
Permanent Establishment exemption: preparing for mandatory application