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Issue 1629
Home
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Issue 1629
Issue 1629
28 July, 2023
Analysis
Reviewing HMRC’s consultation on transfer pricing reform
International review for July 2023
HMRC v Part 26A: can you cram the Crown?
Are retrospective assessments permissible when HMRC didn’t question the tax treatment during prior inspections?
GE Financial, treaty residence, and the meaning of ‘business’
OECD pillar talk: Pillar Two looming; Pillar One a step closer
EU withholding tax: will things move FASTER?
How to handle R&D enquiries
In conversation with... Dan Neidle of Tax Policy Associates
In brief
Self’s assessment: Inheritance tax
Marano: ‘special circumstances’ in penalty cases
When does a payment constitute a distribution?
News
HMRC manual changes: 28 July 2023
Action required on venture capital schemes, says Treasury Committee
Treasury Committee calls for systematic review of tax reliefs
NICs investment zone reliefs for employers
R&D claim requirements confirmed
New transfer pricing records requirements
HMRC issues clarifications on SBAs
CIOT responds to CIS proposals
NICs exemption for pension remedy payments
New guidance on tax refunds for negative earnings
HMRC takes control of IPT forms
Reminder of business/non-business test
UK adopts Pillar Two accounting changes
Luxembourg ratifies UK double tax convention
UK agrees social security convention with EEA
Brazil and San Marino tax agreements given effect
CIOT urges caution with trials on 'innovative' tax policy
HMRC consults on tax and occupational health
CIOT and ATT urge clear, comprehensive guidance on taxation for charities
HMRC brings in extra tax from investigations
Government responds to PAC tax compliance report
Agent Update Issue 110
Cases
M R Currell Ltd v HMRC
I Strachan v HMRC
Sonder Europe Ltd v HMRC
TP v Administration de l’Enregistrement, des Domaines et de la TVA
Ebuyer (UK) Ltd v HMRC
Other cases that caught our eye: 28 July 2023
One minute with
One minute with... Jessica McLellan
Trackers
HMRC manual changes: 28 July 2023
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 consult on taxation of UK-resident members of LLCs and other ‘reverse hybrids’
HMRC phase in mandatory payrolling of benefits from April 2027
ATED pre-return banding checks
Coding out winter fuel payment charge
Pensions advisers urge rethink on IHT
CASES
Read all
HMRC v Bolt Services UK Ltd
Barclays Bank plc v HMRC
HMRC v GCH Corporation Ltd and others
Barclays Services Corporation and another v HMRC
Other cases that caught our eye: 19 June 2026
IN BRIEF
Read all
Foreign PE exemption becoming mandatory
Solving the LLC double taxation problem
AI in R&D advisory: seven control points
Information notices
Management rollovers and share-for-share exchange relief
MOST READ
Read all
Consultation tracker
Lifeplus Europe Ltd v HMRC
Sintra, Hall and the reshaping of HMRC’s burden of proof
Management rollovers and share-for-share exchange relief
The UK’s tax certainty problem