HMRC manual changes: 15 December 2023

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

Direct taxes

Manual	Page	Comments
Capital Allowances Manual	Updated: CA23115	Confirmation that for plant or machinery the First Year Allowance (FYA) leasing exclusion is either entirely applicable or not. There is no provision for partial application. If the asset is mainly intended to be provided with an operator it is generally accepted by HMRC that the leasing exclusion does not apply so that FYAs are due.
International Manual	Added: INTM180050 and INTM180060	Expanded content on foreign entity classification including a new page on HMRC’s view of Delaware LLCs in light of Anson v HMRC [2015] UKSC 44 and a page on...

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

Direct taxes

Manual	Page	Comments
Capital Allowances Manual	Updated: CA23115	Confirmation that for plant or machinery the First Year Allowance (FYA) leasing exclusion is either entirely applicable or not. There is no provision for partial application. If the asset is mainly intended to be provided with an operator it is generally accepted by HMRC that the leasing exclusion does not apply so that FYAs are due.
International Manual	Added: INTM180050 and INTM180060	Expanded content on foreign entity classification including a new page on HMRC’s view of Delaware LLCs in light of Anson v HMRC [2015] UKSC 44 and a page on...