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NEWS
Recent developments in tax.
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...
US Senate passes OBBBA
The US Senate has narrowly approved the One Big Beautiful Bill Act, with Vice-President JD Vance casting the tie-breaking vote. The legislation now returns to the House of Representatives for further scrutiny. President Trump has set a 4 July...
Information exchange rules expanded
The International Tax Compliance (Amendment) Regulations, SI 2025/740, expand the scope of the OECD Common Reporting Standard on the automatic exchange of information to cover electronic money institutions and certain digital money products, exclude...
Tax Journal authors for June
Tax Journal thanks its authors for June (click on links below to view author profiles and access their contributions):James Anderson and Lorenza De Domenico - The Government amendments to domestic Permanent Establishment rulesClaire Ayres -...
HMRC manual changes: 27 June 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Uncollected tax from small businesses rises to 40%
HMRC have released Measuring Tax Gaps 2025, the latest tax gap estimates, covering 2023/24. Headline statistics include the overall tax gap which was 5.3% of total theoretical tax liabilities (£46.8bn), up from 4.8% (£39.8bn) in the previous...
New clearance system should cover all taxes, says CIOT
The CIOT has responded to the Treasury consultation on advance tax certainty for major projects. Key points include: the new process should ensure a focus on key projects and issues that will impact investment decisions; it is accepted that any new...
Judicial review of APR/BPR launched
Law firm Collyer Bristow has started proceedings for the judicial review of the Government’s decision not to consult on its proposed changes to IHT agricultural and business property reliefs, in breach of the Government’s own consultation...
Reform UK’s proposes new ‘Britannia card’
Reform UK has proposed a new ‘Britannia Card’ which would reintroduce a non-dom status in return for a £250,000 fee. Funds raised each year would be pooled and paid out by HMRC as a ‘Robin Hood’ style ‘cash dividend’ to the ‘bottom 10% of working...
VAT deduction on the management of pension funds
Revenue & Customs Brief 4/2025 on VAT deduction on the management of pension funds announces that HMRC will no longer view investment costs as being subject to dual use. Instead, all the associated input tax incurred will be seen as the employer’s...
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EDITOR'S PICK
The new Securities Transfer Tax: business as usual?
Georgina West
1 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
2 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
3 /7
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
4 /7
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
,
Ian Zeider
5 /7
Estoppel and abuse of process in VAT
Claire Logan
6 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
7 /7
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
Let the light in: LLCs and other reverse hybrids
Matthew Rowbotham
HFFX: the widening reach of miscellaneous income
Elena Rowlands
,
Tom Margesson
Estoppel and abuse of process in VAT
Claire Logan
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
NEWS
Read all
CGT liabilities rise 89% to record £24.2bn
Pubs and hotels business rates: methodology call for evidence
Technical Note 2 for IHT on pensions
CIOT outlines support for extension of VAT online marketplace rules
VAT relief could remove barriers to social housing
CASES
Read all
Knights Developments Ltd v HMRC
A Pontin and others v HMRC
AXA Insurance UK plc and another v HMRC and another
HMRC v G Quillan
Perenco UK Ltd v HMRC
IN BRIEF
Read all
Sanctionable conduct
The end of offshore execution on secondary transactions
Tax adviser registration: deferral for investment managers
When is a trustee not a trustee?
Funding the business
MOST READ
Read all
Property 118 Ltd and another v HMRC
The end of offshore execution on secondary transactions
Perenco UK Ltd v HMRC
When is a trustee not a trustee?
Tax adviser registration: deferral for investment managers