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Private client review for February 2025

Remittances, restlessness and reform are just some of the topics covered in this month’s review, by Sophie Dworetzsky and Dominic Lawrance (Charles Russell Speechlys).

Remittances restlessness and reform

A number of profoundly troubling drafting defects – it is hoped they are drafting defects rather than deliberate manifestations of policy – have been identified in the Finance Bill. These changes have been incorporated into the Finance Bill 2024/25 (Sch 9 Part I).

Representations have been made by the professional bodies to HMRC and it appears that some of these defects may be rectified according to an article in the Financial Times of 11 February. For present purposes we highlight the key issues and it is to be hoped that an updated version of the Finance Bill will be released shortly with these issues resolved.

Perhaps the most pernicious issue arises under new s 809L(9A)(b). This provision states references...

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