Issue 1701

Analysis

• Elborne: trusting that the loan will be deducted
• Bryan Robson: when image and IR35 don’t mix
• EIS disqualifying arrangements: jumping through the Hoopla
• Private client review for March 2025
• Criminal offences and prosecutions for tax fraud

In brief

• When is 20% not 20%?
• Are multiple trusts still a viable IHT planning strategy?
• Avoid shareholder debt write-offs in corporate transactions

News

• HMRC manual changes: 21 March 2025
• Concerns remain over Making Tax Digital
• Economic crime regulations issued
• Reduction in Class 1 NICs secondary threshold
• Scottish Landfill Communities Fund consultation
• UK revokes Russia and Belarus DTTs
• Single Customer Account update

Cases

• Orsted West of Duddon Sands (UK) Ltd and others v HMRC
• B Lynch v HMRC
• V Louwman v HMRC
• A Sajedi and others v HMRC
• Other cases that caught our eye: 21 March 2025

One minute with

• One minute with... Majid Hussain

Trackers

• HMRC manual changes: 21 March 2025