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NEWS
Recent developments in tax.
HMRC manual changes: 4 April 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
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...
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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