Issue 1738

Analysis

• A Budget for its times? The Scottish Budget 2026/27
• A new service for tax certainty on major projects
• Private client review for January 2026
• Home offices and hard rocks: the 2025 Update to the OECD’s Model Tax Convention
• EOTs: are they still one of the best ways to sell your company to its employees?

News

• HMRC manual changes: 23 January 2026
• New PCRT guidance clarifies ethical limits on AI use in tax
• Imported hybrid mismatches
• Voluntary NI contributions for periods abroad
• Transfer Pricing Guidelines for Compliance
• Scottish Landfill Tax
• £3.5bn PAYE overpayment
• HMRC win less than 38% of appeals against automated penalties
• Preparing for MTD for Income Tax
• Cash ISA reforms may add complexity, Treasury Committee warns
• National Insurance Bill nears Commons completion

Cases

• HMRC v MedPro Healthcare
• J O’Neil and others v HMRC
• R (oao Peter Kadas) v HMRC
• Other cases that caught our eye: 23 January 2026

One minute with

• One minute with... Dilpreet K Dhanoa

Trackers

• HMRC manual changes: 23 January 2026