Issue 1687

Analysis

• The new Overseas Workday Relief regime: worse than before?
• A new chapter in the unallowable purpose tale: the FTT’s decision in Syngenta
• AI in tax administration: the need for taxpayer safeguards
• The Upper Tribunal’s ruling in Gould on interim dividends
• Private client review for November 2024

In brief

• Self’s assessment: Reforms to APR
• Greater taxpayer success under internal HMRC reviews
• Can a compromise on APR be achieved?

News

• 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
• Reporting of offshore interest
• Further lifetime allowance changes
• Private school fees and VAT treatment of therapy services
• UK signs new double tax treaty with Romania
• Finance Bill 2025 update
• MPs call for independent taxpayer advocate service
• HMRC review proves successful for taxpayers
• Gibraltar financial services ‘passporting’ rights extended

Cases

• R (oao Refinitiv Ltd and others) v HMRC
• Generator Power Ltd v HMRC
• Other cases that caught our eye: 22 November 2024

One minute with

• One minute with... Jacquelyn Kimber

Trackers

• HMRC manual changes: 22 November 2024
• Consultation tracker
• Tax watch: 22 November 2024
• Case watch