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NEWS
Recent developments in tax.
REITs falling foul of tax rules
HMRC data suggests that the number of real estate investment trusts (REITs) in breach of the conditions for their special tax status has nearly quadrupled over the last year, according to analysis by law firm BCLP (Bryan Cave Leighton Paisner). The...
HMRC manual changes: 4 July 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
G7 agreement removes US ‘retaliatory’ tax
The G7 has reached agreement on the application of the global minimum tax under Pillar Two, including the removal of section 899 from the US One Big Beautiful Bill a retaliatory tax provision designed to increase tax on foreign...
Cryptoasset reporting requirements introduced
The Reporting Cryptoasset Service Providers (Due Diligence and Reporting Requirements) Regulations, SI 2025/744, will require UK businesses which transfer relevant cryptoassets, or exchange relevant cryptoassets for other cryptoassets, government...
Rise in transfer pricing tax demands but fines slump
Data obtained by LCN Legal under the Freedom of Information Act suggests that HMRC have been taking a light-touch approach to transfer pricing cases, with penalties for non-compliance with the UK rules either so small as to be non-disclosable or...
Class 2 NICs error corrected, say HMRC
Following concerns previously raised around errors in some Class 2 NICs computations, the ATT reports having received confirmation from HMRC that no further action is now required by agents who have received incorrect calculations for their clients....
PISCES stamp taxes exemption introduced
The Private Intermittent Securities and Capital Exchange System (Exemption from Stamp Duties) Regulations, SI 2025/666, introduce an exemption from stamp duties on transfers of shares in connection with trading activity that takes place on a Private...
Technical changes to ISA rules
The Individual Savings Account (Amendment) Regulations, SI 2025/733, introduce various changes to the principal ISA regulations (SI 1998/1870). Among the more notable amendments are the new requirement for national insurance information to have been...
CIOT flags non-dom uncertainties
In a proactive and detailed submission, the CIOT highlights various issues related to the non-dom reforms ‘that may require legislative change and other areas of uncertainty’. On the foreign income and gains (FIG) regime, consideration should be...
US Senate passes OBBBA
The US Senate has narrowly approved the One Big Beautiful Bill Act, with Vice-President JD Vance casting the tie-breaking vote. The legislation now returns to the House of Representatives for further scrutiny. President Trump has set a 4 July...
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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
HMRC manual changes: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
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
The new share for share anti-avoidance
Concerns over the scope of new conduct rules for advisers
HMRC v Sintra Global Inc and another
HMRC manual changes: 9 January 2026
Complex statutory construction: the Court of Appeal’s approach in Tower One