Issue 1698

Analysis

• Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
• Tax grouping (part II): capital gains groups
• Yorkshire Agricultural Society, consistent interpretation and the continued relevance of EU law
• Judicial review in tax disputes
• International review for February 2025

In brief

• Statutory residence: but why do you need to be here?
• Ramsay reined in?
• HMRC’s focus on PE firms’ VAT compliance
• HMRC’s U-turn on limited partners

News

• HMRC manual changes: 28 February 2025
• Government proposes further Finance Bill amendments, including to the temporary repatriation facility
• Business rates relief for film studios
• HMRC advisory fuel rates
• Scottish landfill tax rates
• UK-Andorra Double Tax Convention signed
• Final Welsh Budget 2025/26 tabled
• HMRC and electronic delivery of information
• Transfers into employee trusts to reduce IHT are ‘abnormal’ arrangements, says GAAR
• Offshore anti-avoidance legislation is outdated and confusing, says CIOT
• Updated HMRC guidance on managing trust details
• Online marketplace sales targeted in latest nudge letter

Cases

• The executors of L Elborne deceased and others v HMRC
• Chelsea Cloisters Management Ltd v HMRC
• HMRC v Asset House Piccadilly Ltd
• Other cases that caught our eye: 28 February 2025

One minute with

• One minute with... Dominic Robertson

Trackers

• HMRC manual changes: 28 February 2025