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NEWS
Recent developments in tax.
CIOT welcomes HMRC’s international tax proposals
The CIOT has also responded to HMRC’s consultation on transfer pricing, permanent establishment and diverted profits tax which closed on 7 July. On transfer pricing and the general exemption for UK, the UK transfer pricing is considered a positive...
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...
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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
Consultation tracker