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NEWS
Recent developments in tax.
Urgent action could be required on non-dom ‘double remittances’
The CIOT has published a paper outlining concerns around HMRC’s position on the treatment of re-remittances of foreign income or gains on or after 6 April 2025. Recent discussions revealed HMRC’s view that funds previously remitted to the UK are only...
HMRC set out Pillar Two territories
The Multinational Top-up Tax (Pillar Two Territories, Qualifying Domestic Top-up Taxes and Accredited Qualifying Domestic Top-up Taxes) Regulations, SI 2025/406, set out the list of territories which have qualifying income inclusion rules and...
Additional information requirements for creative industry claims updated
The Relief for Creative Industries (Additional Information Requirements and Miscellaneous Amendments) (Amendment) Regulations, SI 2025/383, update the additional information required to be submitted in support of creative sector tax relief claims on...
Private schools VAT challenge
The judicial review of the UK Government’s removal of the VAT exemption for private school fees was scheduled to be heard before the High Court between 1 and 3 April 2025.The claim challenges the decision on several grounds, including that taxing the...
HMRC increase late-payment interest rates
The Taxes and Duties, etc (Interest Rate) (Amendment) Regulations, SI 2025/386, amend the formulas for calculating the various rates of late-payment interest charged on amounts due to HMRC – the effect being to increase those rates by 1.5 percentage...
MTD: late-payment penalties to be increased
The Finance Act 2021 (Amendment of Schedule 26 Penalty Figures) (Appointed Day: Regulation Making Power) Regulations, SI 2025/399, enable changes to be made to the MTD penalties regime, as announced by the Chancellor at Spring Statement 2025. The...
Employment Related Securities Bulletin 59
HMRC’s March 2025 Bulletin provides several key updates, including: Private Intermittent Securities and Capital Exchange System (PISCES): a general update on the introduction of PISCES, a new stock market for secondary trading of private company...
CIOT responds to Scottish Budget inquiry
In its response to the Finance and Public Administration Committee of the Scottish Parliament’s Inquiry into the Scottish Budget process in practice, the CIOT makes several key points: a legislative vehicle, such as an annual finance or tax Bill to...
HMRC highlight avoidance scheme
HMRC have added Spotlight 68 to their collection, summarising a marketed scheme which aims to reduce corporation tax liabilities by including ‘advertising’ expenses in the company’s profit and loss account. Under the arrangements, the company deducts...
HMRC issue new Directions for R&D claim notifications
HMRC have issued new Directions requiring the electronic delivery of R&D claim notifications, additional information in support of claims, ‘Chapter 2 relief’ notifications (Northern Ireland companies), and amendments to company tax returns which...
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 25 April 2025
DST was always meant to be temporary, says Exchequer Secretary
HMRC change approach to CIR reporting
R&D relief: HMRC to update guidance on going concern rules and intra-group transfers
Pre-development costs consultation postponed
CASES
Read all
WTGIL Ltd v HMRC
Vaccine Research Limited Partnership and another v HMRC
George Mantides Ltd v HMRC
Refinitiv Ltd and others v HMRC
Other cases that caught our eye: 25 April 2025
IN BRIEF
Read all
A statutory residence test bear-trap
Protected income and offshore income gains
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
MOST READ
Read all
VAT road fuel scale charges updated
FA 2025 review: VAT on private school fees: a lack of clarity
FA 2025 review: The loans to participators regime no more (re)paying your way
FA 2025 review: The new FIG regime: who are the real winners?
Loan Charge review: call for evidence