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NEWS
Recent developments in tax.
HMRC and electronic delivery of information
The Income and Corporation Taxes (Electronic Communications) (Amendment) Regulations, SI 2025/172, make the following two changes to the principal electronic communications regulations (SI 2003/282) with effect from 11 March 2025: the delivery of...
Transfers into employee trusts to reduce IHT are ‘abnormal’ arrangements, says GAAR
HMRC have published the GAAR Advisory Panel’s opinion on arrangements involving transfers of amounts into employee trusts (IHTA 1984 s 28) which sought to reduce or eliminate IHT. The deceased had put around £1m into a company she had set up. The...
Offshore anti-avoidance legislation is outdated and confusing, says CIOT
The CIOT notes that the current offshore anti-avoidance provisions are outdated and confusing, suggesting that the various legislative provisions should instead be unified into one anti-avoidance code applying for income and capital gains from...
Updated HMRC guidance on managing trust details
HMRC have updated their guidance on the online tool ‘Manage your trust’s details’. The updated guidance confirms which details can and cannot be changed using the online service by lead trustees, settlors, protectors or other individuals. Information...
Online marketplace sales targeted in latest nudge letter
HMRC are writing to individuals whom they suspect are operating in the hidden economy and who have not reported their income to HMRC for the period up to the tax year ending 5 April 2023. This is based on data HMRC have received from online...
HMRC manual changes: 21 February 2025
This roundup sets out the most important changes to HMRC manuals over the past week as curated by our editors.
HMRC launch e-invoicing consultation
HMRC and the Department for Business and Trade (DBT) have jointly launched a 12-week consultation on electronic invoicing, which the UK government hopes will reduce paperwork for businesses and enhance productivity. E-invoicing will be particularly...
NICs relief in special tax sites: postcode requirement introduced
The Social Security (Contributions) (Amendment) Regulations, SI 2025/144, impose a new reporting requirement for employers which operate in designated special tax sites within a freeport or investment zone, and claim the zero rate of secondary Class...
Company size thresholds apply for off-payroll working rules
The financial thresholds for determining the size of a company under the off-payroll working rules are set to increase from 6 April 2025. The substantive changes to the turnover and balance sheet thresholds were made by SI 2024/1303 to Part 15 of the...
Paying voluntary NICs when abroad
HMRC have issued updated guidance on applications to pay voluntary NICs when abroad. The section which had noted that individuals should apply by post if they had previously paid three years of social security contributions in certain other countries...
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EDITOR'S PICK
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
1 /7
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
2 /7
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
3 /7
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
4 /7
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
5 /7
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
6 /7
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
7 /7
RBC: from the island of literal interpretation to the continental shelf
Victoria Hine
,
Kyle Rainsford
Cross-border group relief: Lloyds tripped up by the ‘main purpose’ hurdle
Gerald Montagu
Helping vulnerable individuals: a guide for tax professionals
Chris Holmes
,
Dawn Register
A ‘significant’ change in approach? Reflections on the Court of Appeal’s decision in BlueCrest
David Haworth
,
David Haughey
ScottishPower and the limits of von Glehn
Rupert Shiers
,
Suzanne Hill
Enhancing UK tax policy: how to stimulate business investment and economic growth
Donald Simpson
Buckle up your seatbelts: why 2025 will be a bumpy ride for US tax policy
Donald L Korb
,
Andrew Solomon
NEWS
Read all
HMRC manual changes: 4 April 2025
Urgent action could be required on non-dom ‘double remittances’
HMRC set out Pillar Two territories
Additional information requirements for creative industry claims updated
Private schools VAT challenge
CASES
Read all
St Patrick’s International College Ltd and others v HMRC
Morgan Lloyd Trustees Ltd v HMRC
HMRC v Bolt Services UK Ltd
Other cases that caught our eye: 4 April 2025
HMRC v Innovative Bites Ltd and another
IN BRIEF
Read all
Excluded property trusts and 6 April 2025
IR35, staffing companies and the small company threshold
Country-by-country reporting goes public
When is 20% not 20%?
Are multiple trusts still a viable IHT planning strategy?
MOST READ
Read all
HMRC closing in on tax avoidance (again)
HMRC v Innovative Bites Ltd and another
Excluded property trusts and 6 April 2025
Country-by-country reporting goes public
Chancellor hints on digital services tax