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NEWS
Recent developments in tax.
CIOT on tax barriers to housing supply
The CIOT has made a written submission on the tax barriers to housing supply, which includes detailed discussion of the CGT, SDLT and VAT issues arising from neighbouring land owners acting together to secure a land sale. ‘Tax Barriers to Housing...
Repayment interest and commercial restitution for VAT
In a Budget representation on repayment interest and commercial restitution for VAT, the CIOT sets out its rationale for the need to review repayment interest and address the inequity brought about by the late-payment interest regime as it applies to...
Italy plans to raise flat tax for wealthy new residents by 50%
In its draft 2026 Budget plans, the Italian Government is proposing to raise the annual flat tax for new wealthy residents from €200,000 to €300,000 from 2026. The measure targets those relocating to Italy and paying the fixed tax on foreign income,...
EU publishes updated list of noncooperative jurisdictions
The EU has updated the EU list of non-cooperative tax jurisdictions. Annex I remains unchanged, currently comprising 11 jurisdictions. Vietnam has been removed from Annex II after successfully implementing the OECD’s BEPS minimum standard on...
New UK-Portugal DTC signed
The UK and Portugal have agreed a new Double Taxation Convention, replacing the previous 1968 agreement between the two countries. Although the Convention was signed in September 2025, it will not enter into force until the completion of all...
Updated list of Pillar Two territories and taxes
HMRC have updated ‘Notice 2: Pillar Two top-up taxes relevant territories and taxes’, adding to the lists of territories which have implemented Pillar Two rules and are specified for the purposes of Multinational Top-up Tax and Domestic Top-up...
Reintroduce certificates of tax deposit, says CIOT
In a Budget representation, the CIOT calls for the Treasury to reintroduce certificates of tax deposit (CTDs). The scheme closed for new purchases on 23 November 2017, although HMRC continued to honour existing certificates until 23 November...
HMRC increase yield from under-reported gains
Recent data shows that HMRC collected £256m from more than 10,000 CGT compliance checks in 2024/25, the highest total in recent years. The figures, acquired by law firm BCLP, show that HMRC compliance checks increased by around 30% compared to the...
HMRC manual changes: 24 October 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
HMRC manual changes: 17 October 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
L Rowland & Co (Retail) Ltd v HMRC