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NEWS
Recent developments in tax.
Double tax conventions come into force
HMRC have added the UK’s new double tax conventions with Andorra, Portugal and Romania to its tax treaties collection, confirming that all three entered into force in December 2025. The conventions take effect in the UK from 1 January 2026 for...
Finance Bill progress
Finance Bill 2026 passed the Committee of the Whole House stage on 12 and 13 January 2026 unamended save for the six government amendments to Sch 12, which increase the cap on the amount of 100% business and agricultural property relief from the...
Professional bodies issue FB 2026 briefings
The CIOT has released four briefings (available in its ‘Finance Bill 2025/26 briefings collection’) on: income tax rate changes for property, savings and dividends (warning of added complexity and potential extra workload for HMRC); IHT changes to...
MTD exemptions guidance
Updated HMRC guidance on exemptions from Making Tax Digital for Income Tax clarifies that agents should use the Agent Dedicated Line to apply for, or appeal against refusal of, digital exclusion exemptions. The guidance also confirms that...
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...
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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: 6 February 2026
Finance Bill measures risk uncertainty, complexity and unintended effects, CIOT warns
Finance Bill round-up
Net settlement and annual reporting requirements
Companies now required to maintain own register of members
CASES
Read all
FS Commercial Ltd v HMRC
P Kearney v HMRC
Mark Glenn Ltd v HMRC
J Hall v HMRC
Other cases that caught our eye: 6 February 2026
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
M Holden v HMRC and HMRC v The Boston Consulting Group UK LLP and others
COP 9 and serious tax fraud: HMRC’s tougher approach
One minute with... Hayley Ives
Consultation tracker
Nimbus: The Disability Consultancy Service Ltd v HMRC