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The OECD will hold a public consultation meeting in Paris on 9 November on proposed revisions to Chapter VII of its Transfer Pricing Guidelines which covers intra-group services. The meeting follows the OECD’s June consultation and publication of responses on 24 August. The proposed revisions are intended to...
HMRC have published guidance on the administration of the loan charge settlement scheme noting that they have started issuing formal settlement offers. Those receiving an offer will have at least 90 days to accept it. Most people with an open enquiry or an appeal not notified to the First-tier...
The Government has launched a consultation on modernising corporate reporting exploring how reporting obligations could be simplified and made more proportionate by clarifying their purpose rationalising thresholds and exemptions and reducing duplication. The proposals cover the corporate reporting framework financial and non-financial reporting corporate...
Professional bodies have reported a possible change to HMRC helpline security checks potentially connected with mandatory tax adviser registration. CIOT and ATT members say that staff on some helplines have requested an Agent Reference Number (ARN) before discussing a client query. The ATT expects HMRC to update their...
HMRC have updated their tax adviser registration guidance urging advisers who missed their registration window or are new to the market to register now. The registration window for advisers with a self-assessment or corporation tax account opened on 18 August. Later starting dates apply to businesses providing only...
Large real estate groups face greater HMRC scrutiny at a time when the department is increasingly declining to confirm the tax treatment of proposed transactions according to law firm BCLP. The firm said that in 2025/26 HMRC had £645m of tax under consideration in relation to the...
Capital repayment by a UK limited company not excluded from Transactions in Securities regime
Loan charge determinations upheld as Ramsay requires genuine economic cost
Entitlement to BADR formed part of the subject matter of closure notice
Whether property was non-residential
