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Issue
1691
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Issue
1691
Issue 1691
10 January, 2025
Analysis
Succession planning: the longer-term impact of the Budget on businesses
The sale of occupational income provisions following Grint
Corporate re-domiciliation Panel Report: potential impact on structuring inward bound re-domiciliation
HMRC’s defeats on subsidised and contracted out R&D
In brief
Balancing growth and taxes: the corporate tax roadmap
The increased interest rate on late payments
News
HMRC manual changes: 10 January 2025
HMRC names new Perm Sec
HMRC are not appealing decisions on R&D subsidies and contracting out
New guidance on refund claims for overpaid PAYE
Digital platform operators reporting reminders
Car and van benefit amounts updated
HMRC revise employment expenses process ... again
Companies register: protection of addresses
HMRC clarify VAT treatment of remedial building works
Challenge to VAT on private school fees
Voluntary disclosures of offshore income up 22%
UK-Ecuador agreement given effect
OECD releases Amount B tool and factsheets
Exchange of information on tax rulings: peer reviews
Chancellor commissions Spring Forecast
Finance Bill 2025: Public Bill Committee to begin in January
NICs Bill progresses to Lords stages
Updated guideline hourly rates for tribunal costs applications
Agent Update: Issue 126
HMRC Stakeholder Digest: 19 December 2024
HMRC press officer contact details updated
Cases
JTC Employer Solutions Trustee Ltd and others v W Garnett and others
M R Currell Ltd v HMRC
NHS Mid & South Essex ICB and others v HMRC
Chemidex Generics Ltd v HMRC
FRF (South Wales) Ltd v HMRC
Other cases that caught our eye: 10 January 2025
One minute with
One minute with... Giles Hambly
Trackers
HMRC manual changes: 10 January 2025
EDITOR'S PICK
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
1 /7
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
,
Ollie Winters
2 /7
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
3 /7
Loopholes and tax avoidance
Kyle Rainsford
4 /7
Spare us the cUTTer
Nick Thornton
5 /7
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
6 /7
Muller: notional companies and real-world transactions
Ashley Greenbank
7 /7
The UK’s tax certainty problem
Jenny Batchelor
,
Ahmed Mobasshir
HMRC’s status in Part 26A restructuring plans: the High Court decision in Waldorf
Alan Rafferty
,
Jade Du Berry
Ask an expert: Dividend planning under the new close company reporting regime
Nick Wright
Loopholes and tax avoidance
Kyle Rainsford
Spare us the cUTTer
Nick Thornton
PGMOL: where the FTT decision may be vulnerable on appeal
Rebecca Seeley Harris
Muller: notional companies and real-world transactions
Ashley Greenbank
NEWS
Read all
HMRC confirm transitional approach to Pillar Two filing penalties
CIOT urges reform of CIS landlord payment rules
HMRC publish capital v revenue expenditure toolkit
New SDLT guidance published
Updated Directions on employee expenses
CASES
Read all
Swiss Centre Ltd v HMRC
L Henry v HMRC
Winchester City Council v HMRC
Other cases that caught our eye: 3 July 2026
HMRC v HFFX LLP; Atkins and others v HMRC
IN BRIEF
Read all
Tax Update 2026: Plans to reform the income tax payment regime: a significant acceleration of ITSA tax liabilities
Tax Update 2026: Modernising the distributions framework: familiar routes for extracting value or reorganising companies may change
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
MOST READ
Read all
Consultation tracker
HMRC consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
The Trustees of the Panico Panayi Accumulation and Maintenance Settlements Nos. 1 to 4 v HMRC and Redevco Properties UK 1 Ltd v HMRC
HMRC v HFFX LLP; Atkins and others v HMRC
HFFX: the widening reach of miscellaneous income