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NEWS
Recent developments in tax.
Agent Update 123
HMRC’s Agent Update 123 for September 2024 covers a range of recent developments, including the following key points:reminder of the updated additional information required alongside R&D claims under the April 2024 regime, noting that the additional...
Pension Schemes Newsletter 162
HMRCs latest newsletter confirms that regulations will be introduced as soon as parliamentary time allows to correct the pensions lifetime allowance abolition legislation (following the recent consultation with industry)....
HMRC criminal investigations bring in £1bn
Pinsent Masons reports that HMRCs serious criminal tax investigations brought in 991m in 2023/24, up from just 89m in the previous tax year. 653m of that total came from HMRCs case against Bernie Ecclestone but the...
HMRC pursue company directors
HMRC have significantly increased their use of joint and several liability notices to recover tax debts from individual directors where the company has become, or is likely to become, insolvent. Pinsent Masons highlights a 225% increase, with...
HMRC manual changes: 20 September 2024
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
Business Tax Roadmap: stability is key, says CIOT
The Chancellor has already confirmed that the Business Tax Roadmap is to be included in the 30 October 2024 Budget. Welcoming that commitment, the CIOT highlights points of key importance for business and the tax profession:The overwhelming feedback...
HMRC’s new transfer pricing guidelines ‘suggest more aggressive approach’
HMRCs new guidelines for compliance on transfer pricing (CfC7), published last week, suggests a more aggressive approach to tax enforcement, says LCN Legal, a firmspecialising in providing intercompany agreements for MNEs.Paul...
R&D information requirements revised
The Research and Development Relief (Information Requirements etc) Regulations, SI 2024/950, rewrite the requirements for information that must be submitted by companies in support of their RD claims, following introduction of the new RD...
Fractional shares in ISAs to be allowed
HMRC have confirmed that savers will be able to hold fractional shares in ISAs. The Conservative government originally announced this change in the 2023 Autumn Statement, but it was put on hold as a result of the 2024 general election. After some...
CIOT seeks clarity on ‘ordinary share capital’
In a proactive submission, the CIOT is seeking clarification of HMRCs position on whether non-cumulative shares with a fixed-rate dividend would still be regarded as ordinary share capital for the purposes of ITA 2007 s 989.HMRCs...
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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
EOT tax relief too narrow, suggests CIOT
Tax reliefs confirmed for special tax sites in Wales
Updated advisory fuel rates published
IHT should apply equally across all assets, says IFS
Scottish aggregates tax on the horizon
CASES
Read all
R (oao Cobalt Data Centre 2 LLP and another) v HMRC
The Tower One St George Wharf Ltd v HMRC
HMRC v The Taxpayer and others
R (oao Refinitiv Ltd and others) v HMRC
Generator Power Ltd v HMRC
IN BRIEF
Read all
Refinitiv: not so clear cut
The complexities of APR and IHT for family farms
Self’s assessment: Reforms to APR
Greater taxpayer success under internal HMRC reviews
Can a compromise on APR be achieved?
MOST READ
Read all
Syngenta Holdings Ltd v HMRC
Finance Bill 2025 published
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC
UK signs new double tax treaty with Romania
Autumn Budget 2024: IHT winners and losers