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NEWS
Recent developments in tax.
HMRC manual changes: 22 November 2024
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Tax increases in Scotland could have led to falling revenue, says IFS
Analysis published by the Institute for Fiscal Studies suggests that increases in the top rate of Scottish income tax may have led to reduced revenues for the Scottish Government. The top rate of tax is set at 48% in 2024/25 and applies to taxable...
NICs Bill published
The National Insurance Contributions (Secondary Class 1 Contributions) Bill was published on 13 November 2024, and will make the following changes from 6 April 2025: increase the main Class 1 secondary rate of NICs to 15% (up from 13.8%); reduce the...
Making Tax Digital: late-payment penalty anomaly corrected
As reported last week, regulations are required to address a potential gap in the legislation which introduced late-payment penalties under the harmonised penalty regime for Making Tax Digital. With the relevant empowering provisions now in force...
Energy security investment mechanism: average prices
The Energy (Oil and Gas) Profits Levy (Energy Security Investment Mechanism) Regulations, SI 2024/1175, set out how the average price of oil and gas over a reference period will be calculated for the purposes of the energy security investment...
Reporting of offshore interest
The ATT highlights HMRC’s Autumn Budget 2024 consultation on Simplifying the Taxation of Offshore Interest. The consultation considers the challenges of offshore interest being reported to both taxpayers and HMRC on a calendar-year basis, and the...
Further lifetime allowance changes
The Pensions (Abolition of Lifetime Allowance Charge etc) (No 3) Regulations, SI 2024/1167, make further changes to the substantive pensions legislation (mainly FA 2004 Sch 29 and 36) in consequence of the abolition of the lifetime allowance. The...
Private school fees and VAT treatment of therapy services
In an important addition to their guidance on the VAT treatment of payments linked to private school fees, HMRC have provided new notes and examples covering situations where pupils receive therapy services in addition to education. The new section...
UK signs new double tax treaty with Romania
HMRC have added the UK-Romania double taxation agreement, as signed on 13 November 2024, to their collection of tax treaties. This new agreement has not yet been brought into force, but will eventually replace the previous 1975 agreement between the...
Finance Bill 2025 update
Second reading of the Bill has been scheduled for 27 November 2024....
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EDITOR'S PICK
Tax Journal's 2024 Autumn Budget coverage
1 /7
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
2 /7
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
3 /7
Freebies
David Whiscombe
4 /7
Time is tight: CGT and the Autumn Budget
Peter Rayney
5 /7
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
6 /7
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
7 /7
Tax Journal's 2024 Autumn Budget coverage
Derivatives, repos and stock loans: an overview
Matthew Mortimer
,
Tamar Ruiz
Lost the battle but winning the war? The Supreme Court’s decision in PGMOL
Georgia Hicks
Freebies
David Whiscombe
Time is tight: CGT and the Autumn Budget
Peter Rayney
What does the future hold for US adoption of the OECD’s two-pillar proposals?
Donald L. Korb
,
Andrew Solomon
The emergence of a ‘new’ fixed establishment threshold for VAT grouping: insights from Barclays
Philippe Gamito
NEWS
Read all
HMRC manual changes: 22 November 2024
Tax increases in Scotland could have led to falling revenue, says IFS
NICs Bill published
Making Tax Digital: late-payment penalty anomaly corrected
Energy security investment mechanism: average prices
CASES
Read all
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
Other cases that caught our eye: 22 November 2024
Syngenta Holdings Ltd v HMRC
The Executors of K Beresford v HMRC
IN BRIEF
Read all
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
Autumn Budget 2024: IHT winners and losers
Corporate redomiciliation
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
Autumn Budget 2024: IHT winners and losers
UK signs new double tax treaty with Romania