Issue 1729

Analysis

• Lifecycle of a transaction: tax disputes on intra-group debt
• Advising non-residents on accessing their UK pensions
• International tax reform: what are the critical issues?
• International review for October 2025

In brief

• ‘Partnership NICs’: the impact on the asset management sector
• Time to bring back Budget purdah?
• Transfer pricing ‘high-value’ intragroup services

News

• Partnership NICs: experts warn of danger to LLP model
• HMRC manual changes: 31 October 2025
• Mandatory director identity verification brought into force
• Single supervisor for anti-money laundering
• HMRC to raise awareness of MTD
• Lords reviews UK fiscal rules
• HMRC issue letters referring to GfC13
• Lords Committee urges rethink on DOTAS criminal offence
• CIOT comments on draft IHT changes
• Small profits rate not available for non-resident companies

Cases

• Illuminate Skin Clinics Ltd v HMRC
• Eurocent (Buckingham) Ltd v HMRC
• Tyler Security Ltd v HMRC
• Other cases that caught our eye: 31 October 2025

One minute with

• One minute with… Nicola Hine

Trackers

• HMRC manual changes: 31 October 2025