Tax News

In this month's episode, Tax associate Stephanie Mullins joins Zoe Andrews to discuss: Key cases: Recent decisions on SDLT overpayment relief in Candy, the capital allowances purpose test in Perenco, the limits of the Ramsay principle in Elborne, and the interpretation of the UK-Isle of Man Double Tax Treaty. UK developments: Our pick of the L-Day developments, together with new or updated HMRC guidance on transfer pricing compliance, VAT on fund management services, the Reserved Investor Fund and anti-avoidance information notices. International spotlight: The draft UN Framework Convention on International Tax Cooperation and its protocols on cross-border services and tax dispute resolution.

In this month's episode, Tax associate Amy Motherwell joins Zoe Andrews to discuss: Key cases: The Supreme Court's decision in HFFX; the Upper Tribunal's decision in Barclays Services Corporation; and the Upper Tribunal's decision in Swiss Centre. UK developments: HMRC's consultation on reducing the high effective tax rates; the surprise consultation on modernising the distributions framework; and HMRC's Transformation Roadmap progress update. International spotlight: The European Commission’s tax simplification package includes a Direct Taxation Omnibus Directive and a DAC recast, which could be adopted by the end of 2026.

For this month’s edition, Gabrielle Pereira and Alex Dustan join Zoe Andrew to discuss: Supreme Court's Gunfleet Sands decision: A restrictive ruling on capital allowances for predevelopment costs  Electricity Generator Levy: Increase from 45% to 55% from July 2026, with voluntary fixed-price contracts Court of Appeal in Burlington : Important clarification of treaty purpose tests, with global implications for the principal purpose test  Court of Appeal in MR Currell : The purpose of a payment does not determine its legal character  VAT classification of Mega Marshmallows (Innovative Bites ): They're zero-rated food, not confectionery  Inbound redomiciliation consultation: Proposals to allow foreign companies to move their place of incorporation to the UK 

For this month’s edition, Ed Milliner joins Zoe Andrews to discuss three cases: Sintra (CA) – burden of proof in tax penalty appeals, Lycamobile (UT) – VAT on bundle plans (and two perfect quotes about VAT…), and Muller (CA) – how the partnership notional company fiction interacts with the intangible fixed assets rules. The podcast then covers various UK tax developments including: tax adviser registration rollout with proposed delay for in house teams in the financial services industry, NAO report on taxing large businesses, and uncertain Tax Treatment consultation on extending the notification regime – including a possible new trigger where HMRC’s position is not known and there is more than one credible legal interpretation.

For this month’s edition, Jamshed Bilimoria joins Zoe Andrews to discuss three cases: Hotel La Tour (Supreme Court judgment on input VAT recovery on deal fees), Tower One St George Wharf (Court of Appeal decision on SDLT and anti‑avoidance) and Font (High Court decision on judicial review in MAP dispute).   The podcast then covers aspects of the Autumn Budget and Finance Bill including: mandatory tax adviser registration, SDRT exemption for newly listed companies, reform of transfer pricing, and permanent establishment (PE) rules; and the new corporation tax charge replacing DPT and changes to the share for share exchange rules and the impact on clearances.   Jamshed and Zoe go on to explore international developments in two areas: the OECD’s global minimum tax “side‑by‑side package” (including new safe harbours and simplification measures) and the OECD updates on global mobility, including when home‑working may (or may not) create a PE.

For this month’s edition, Alex Sim joined Zoe Andrews to discuss three cases of the FTT: Dialog (the tax treatment of break fees), Boulting (purchase of own shares was not a distribution) and Ferrero (the VAT treatment of Nutella biscuits).    The podcast then covers HMRC’s campaign on management expenses and HMRC’s policy (set out in Revenue & Customs Brief 6 (2025)) on VAT deduction on insurance intermediary services supplied outside the UK following the FTT’s decision earlier this year in Hastings Insurance.   Alex and Zoe go on to explore various international developments including the OECD’s recent APA/MAP awards and France’s proposal to double the rate of its digital services tax.

Sarah Osprey joined Zoe Andrews and Tanja Velling to discuss trends in HMRC enquiries and the use of criminal investigation powers in a tax context. The podcast then covers the Supreme Court’s decision in Prudential Assurance on the interaction between the VAT grouping and time of supply rules, and the CJEU’s decision in Arcomet Towercranes that transfer pricing adjustments can trigger VAT liabilities.

Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area. The podcast further covers three decisions of the First-tier Tribunal: Currys Retail on the capital gains tax degrouping charge Millennium Cash & Carry, the first case on the so-called “sugar tax” which highlights the limits of statutory construction Motorplus on VAT recovery with the FTT commenting on HMRC’s extraordinary behaviour Zoe and Tanja go on to discuss L-Day materials including draft legislation for inheritance tax on inherited pension and death benefits, HMRC’s increased powers to close in on promoters, and the mandatory registration requirement for tax advisers interacting with HMRC, as well as certain other UK and international tax developments.

Zoe Andrews and Tanja Velling discuss the following recent cases: Dolphin Drilling: the Supreme Court’s decision on the meaning of “incidental” should not be read as having wider application beyond the oil contractor regime Haworth (Court of Appeal) applying the place of effect management test to a trust in the context of a “round the world” capital gains tax scheme Marlborough DP (Court of Appeal) on the tax treatment of a remuneration structure involving loans made by a trust and the meaning of “in connection with” in Part 7A of ITEPA Osmond: the Upper Tribunal held that it was an error of law to equate seeking a capital gains tax relief with having a main purpose of obtaining an income tax advantage Eastern Power Networks (First-tier Tribunal), a cautionary tale on structuring to maximise consortium relief The podcast also covers HMRC’s new guidance on advance pricing agreements for cost contribution arrangements, the government’s recently published tax policy making principles, Revenue & Customs Brief 4 (2025) on input tax recovery in respect of investment and administration costs linked to occupational pension funds and what’s next for Pillar Two.

Zoe Andrews and Tanja Velling are joined by Arvind Ravichandran, Tax Partner at Cravath, to discuss the impact the proposed section 899 could have on US capital markets if enacted but how it is unlikely to be a big issue in practice. They cover: The purpose and potential withdrawal from the Bill of Section 899, a proposed tax on foreign investors, in response to global tax developments How changes to the GILTI regime aim to more closely align U.S. tax policy with OECD standards The mix of permanent tax cuts and temporary “America First” measures included in the Bill Key negotiation points for Congress including the SALT cap, Medicaid reforms, and clean energy tax credits