Issue 1736

Analysis

• HMRC’s priorities for 2026: building for the future
• Grandfathering
• Share reorganisations: new anti-avoidance rules explained
• Tax and the private capital sector in 2026: three key issues
• Direct and immediate links: the Supreme Court draws the line

News

• HMRC manual changes: 9 January 2026
• Agreement reached on Pillar Two ‘side-by-side’ package
• Late change lifts BPR/APR cap
• New guidelines on imported hybrid mismatch rules
• VAT treatment of supplies of temporary medical staff
• ICAEW warns of ‘existential threat to tax advisers’
• Spring forecast set for 3 March
• PAC to review HMRC’s large business tax compliance
• HMRC trims late-payment interest
• Deadline for trusts to register under automatic exchange regulations
• Festive filers

Cases

• HMRC v Hotel La Tour Ltd
• County Insurance Services Ltd v HMRC
• The Tower One St George Wharf Ltd v HMRC
• R Sehgal v HMRC
• Other cases that caught our eye: 9 January 2026

One minute with

• One minute with... Andrew Callaghan

Trackers

• HMRC manual changes: 9 January 2026