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NEWS
Recent developments in tax.
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...
Rise in VAT receipts
While it is anticipated that the new Prime Minister Liz Truss might soon be looking to making cuts in the VAT rate, research by Thomson Reuters shows that tax collected from VAT in the UK has risen by 60% over the last decade, from 98bn to...
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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?
A Pontin and others v HMRC