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NEWS
Recent developments in tax.
Lump sum payments on divorce
In some welcome news, HMRC have updated their Capital Gains Manual (at CG65356) to clarify that there is no change to their policy on the tax treatment of lump sum payments on divorce relating to the former matrimonial home. ...
Gilt-edged securities list updated
The Taxation of Chargeable Gains (Gilt-edged Securities) Order, SI 2025/553, specifies 14 securities as ‘gilt-edged’ securities for the purposes of TCGA 1992 s 115, meaning that any gains on disposals of those securities are not treated as chargeable...
SAYE scheme bonus rates reduced
HMRC have updated the save as you earn scheme (SAYE) bonus rates following the Bank of England decision on 8 May 2025 to cut the bank base rate to 4.25%. SAYE bonus rates will be reduced to 0.7 for three-year contracts and 1.9 for five-year contracts...
HMRC target VAT grouping ‘avoidance’
HMRC have published Spotlight 70 to bring further attention to the use of VAT grouping arrangements by some residential care providers to enable recovery of VAT on costs which would otherwise not be recoverable. HMRC set out their approach to the VAT...
Updated commentary on GloBE rules
The Inclusive Framework on BEPS has published an updated version of its ‘Consolidated Commentary’ on the GloBE model rules, incorporating agreed administrative guidance up to March 2025 which has been released as jurisdictions have begun to implement...
FTT Direction promotes use of ADR
President of the First-tier Tribunal (Tax Chamber), Judge Amanda Brown KC, has issued a practice statement that sets out how taxpayers and HMRC can turn to Alternative Dispute Resolution (ADR) once a formal appeal is under way (see...
Tribunal power to ‘set aside’ updated
The Tribunal Procedure (Amendment) Rules, SI 2025/561, expressly empower the Upper Tribunal and First-tier Tribunal to set aside a previous decision they have made (i.e. without requiring an application to set aside from one of the parties). The...
HMRC reduce interest rates following base rate cut
HMRC have updated their lists of late-payment and repayment interest rates, following the reduction of the bank base rate to 4.25%. With effect from 28 May 2025, the late-payment interest rate is 8.25% and the repayment rate is 3.25%, for most taxes....
Rise in HMRC ‘dawn raids’
HMRC conducted 648 dawn raids last year, up from 623 raids in the previous year, in their continuing campaign against tax evasion, according to figures obtained by Pinsent Masons. Pinsents note that HMRC have conducted property raids to pursue...
HMRC manual changes: 9 May 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
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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
Staggered roll-out for mandatory tax adviser registration
Consultation on proposed UK corporate re-domiciliation regime
Cryptoassets taxation: stablecoins
Administrative change to CIR rules
NIC regs mirror tax changes
CASES
Read all
HMRC v Colchester Institute Corporation
HMRC v Boehringer Ingelheim Ltd
R (oao Rokos) v HMRC
Other cases that caught our eye: 10 April 2026
HMRC v C Brzezicki
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