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Statutory residence: transit exemption and exceptional circumstances

The knowledge of the hypothetical officer.

This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.

Kyle Rainsford (Addleshaw Goddard) analyses the Court of Appeal’s reasoning on treaty abuse, ‘taking advantage’ and the future interpretation of principal purpose tests.

In a recent SDLT MDR case, the FTT highlights the evidential demands of the ‘being constructed ... for use as a dwelling’ test, revisits the SDLT treatment of options, and adopts an interesting formulation of linked transactions.

Discovery, debt assignment, distribution and penalties: In S Thomas v HMRC [2026] UKFTT 627 (TC) (24 April), the FTT decided that when the company assigned to its controlling shareholder a debt of £2.1m owed to the company by a third party, the...

HMRC have issued a Notice under the International Tax Compliance Regulations, SI 2015/878, reg 1(3)(b), the effect of which is to bring the list of agreements which are within scope of the exchange of tax information up to date to 15 April 2026. In...

The Court of Appeal reins in HMRC’s reading of Rangers, confirming that a genuine EBT loan is not taxable earnings, write Dominic Stuttaford and Katharine Wadia (Norton Rose Fulbright).

HMRC have updated their guidance on the Common Reporting Standard, removing Cameroon and Morocco from the list of ‘reportable jurisdictions’. Financial institutions must report information relating to residents of reportable jurisdictions by 31 May...

Minutes published following an extraordinary meeting of the Working Together Stakeholder Group (WTSG) suggest that HMRC consider the payment of SDLT to constitute an ‘interaction’ with HMRC for the purposes of the new Mandatory Tax Adviser...