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Recent developments in tax.
Managed service companies in the spotlight
HMRC have issued new guidance on managed service companies and MSC providers. Spotlight 67 outlines the characteristics of MSCs and the MSCs tax rules, and provides examples to help identify avoidance schemes. The guidance emphasises that the MSC...
HMRC manual changes: 22 November 2024
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Tax increases in Scotland could have led to falling revenue, says IFS
Analysis published by the Institute for Fiscal Studies suggests that increases in the top rate of Scottish income tax may have led to reduced revenues for the Scottish Government. The top rate of tax is set at 48% in 2024/25 and applies to taxable...
NICs Bill published
The National Insurance Contributions (Secondary Class 1 Contributions) Bill was published on 13 November 2024, and will make the following changes from 6 April 2025: increase the main Class 1 secondary rate of NICs to 15% (up from 13.8%); reduce the...
Making Tax Digital: late-payment penalty anomaly corrected
As reported last week, regulations are required to address a potential gap in the legislation which introduced late-payment penalties under the harmonised penalty regime for Making Tax Digital. With the relevant empowering provisions now in force...
Energy security investment mechanism: average prices
The Energy (Oil and Gas) Profits Levy (Energy Security Investment Mechanism) Regulations, SI 2024/1175, set out how the average price of oil and gas over a reference period will be calculated for the purposes of the energy security investment...
Reporting of offshore interest
The ATT highlights HMRC’s Autumn Budget 2024 consultation on Simplifying the Taxation of Offshore Interest. The consultation considers the challenges of offshore interest being reported to both taxpayers and HMRC on a calendar-year basis, and the...
Further lifetime allowance changes
The Pensions (Abolition of Lifetime Allowance Charge etc) (No 3) Regulations, SI 2024/1167, make further changes to the substantive pensions legislation (mainly FA 2004 Sch 29 and 36) in consequence of the abolition of the lifetime allowance. The...
Private school fees and VAT treatment of therapy services
In an important addition to their guidance on the VAT treatment of payments linked to private school fees, HMRC have provided new notes and examples covering situations where pupils receive therapy services in addition to education. The new section...
UK signs new double tax treaty with Romania
HMRC have added the UK-Romania double taxation agreement, as signed on 13 November 2024, to their collection of tax treaties. This new agreement has not yet been brought into force, but will eventually replace the previous 1975 agreement between the...
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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: 23 January 2026
New PCRT guidance clarifies ethical limits on AI use in tax
Imported hybrid mismatches
Voluntary NI contributions for periods abroad
Transfer Pricing Guidelines for Compliance
CASES
Read all
HMRC v MedPro Healthcare
J O’Neil and others v HMRC
R (oao Peter Kadas) v HMRC
Other cases that caught our eye: 23 January 2026
HMRC v Sintra Global Inc and another
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
The new share for share anti-avoidance
Concerns over the scope of new conduct rules for advisers
HMRC v Sintra Global Inc and another
Complex statutory construction: the Court of Appeal’s approach in Tower One
HMRC manual changes: 9 January 2026