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NEWS
Recent developments in tax.
IHT on cryptoassets nudge letter
HMRC’s Wealthy Team are sending letters to agents who complete IHT forms (IHT400s) on behalf of their clients, reminding them of the need to include cryptoassets where relevant....
HMRC manual changes: 9 January 2026
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Agreement reached on Pillar Two ‘side-by-side’ package
Members of the OECD Inclusive Framework on BEPS have agreed several new safe harbours as part of a package of measures on the global minimum tax rules, the most eye-catching of which would exclude US-headquartered groups from the scope of the Pillar...
Late change lifts BPR/APR cap
As announced in late December 2025, the Government will increase the amount of BPR/APR available at 100% from £1m to £2.5m – allowing spouses or civil partners to pass on up to £5m in qualifying agricultural or business assets between them. Six...
New guidelines on imported hybrid mismatch rules
HMRC have added a new set of guidance to their Guidelines for Compliance series. Help with imported hybrid mismatches: GfC16 is aimed at multinationals dealing with the imported hybrid mismatch rules in TIOPA 2010 Part 6A Chapter 11. The Guidelines...
VAT treatment of supplies of temporary medical staff
HMRC have changed their position on the VAT treatment of supplies of temporary medical staff, following a recent tribunal decision. Revenue & Customs Brief 9/25 sets out HMRC’s view, following the First-tier Tribunal decision in Isle of Wight NHS...
ICAEW warns of ‘existential threat to tax advisers’
The ICAEW has set out concerns with the following Finance Bill 2026 measures: Mandatory registration of tax advisers: meeting HMRC’s minimum standards may not always be straightforward, suggests the Institute, given that the requirements will include...
Spring forecast set for 3 March
The Chancellor will make a statement to Parliament on 3 March 2026, in response to an economic and fiscal forecast to be published by the Office for Budget Responsibility on the same day. The Spring forecast will provide an interim update on the...
PAC to review HMRC’s large business tax compliance
The Public Accounts Committee is inviting submissions of evidence (by 5 March 2026) as part of its enquiry into large business tax compliance, launched in December 2025. That enquiry will also consider the NAO review of whether HMRC’s approach to...
HMRC trims late-payment interest
HMRC are reducing their late-payment and repayment interest rates, following the Bank of England’s decision in December 2025 to cut bank base rate by 0.25 percentage points to 3.75%. For most taxes and payments, the late-payment interest rate will be...
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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
HMRC v Sintra Global Inc and another
Concerns over the scope of new conduct rules for advisers
Complex statutory construction: the Court of Appeal’s approach in Tower One
HMRC manual changes: 9 January 2026