In The Tower One St George Wharf Limited v HMRC [2025] EWCA Civ 1588, the Court of Appeal (CoA) found that a series of transactions involving the grant and transfer of a property lease amongst group companies triggered Stamp Duty Land Tax (SDLT) anti-avoidance provisions.
Following the Bank of England’s announcement on 18 December 2025 that the base rate would decrease to 3.75%, HMRC's interest rates are also decreasing by 0.25%, to 7.75% for late payment interest and 2.75% for repayment interest, from 9 January 2026.
The OECD has released an updated version of the Model Tax Convention on Income and Capital, with clarification around remote working arrangements. The OECD Model incorporates the latest developments in international taxation and provides guidance on interpreting and applying bilateral tax treaties.
In Timothy Watts v HMRC [2025] EWCA Civ 1615, the Court of Appeal (CoA) found that Income Tax relief for losses on gilt strips was confined to real economic losses, and could not be generated by fragmenting consideration within a pre-planned avoidance scheme.
The government has announced that the proposed cap to the 100% rates of Agricultural Property Relief (APR) and Business Property Relief (BPR), which is due to apply from 6 April 2026, will be increased to £2.5 million from the £1 million previously announced.
The Chancellor, Rachel Reeves, has asked the Office for Budget Responsibility (OBR) to prepare an economic and fiscal forecast for publication on 3 March 2026, the date of the 2026 Spring Forecast.
Hello,
In our last update of 2025, we report on an important but little-known 31 December 2025 registration deadline for some trusts and other entities, the December Employer Bulletin, VAT in the context of rotisserie chickens, and Inheritance Tax on Income Tax repayments due to an estate.
Changes made to the Automatic Exchange of Information (AEOI) regulations earlier this year mean that trusts and other entities considered to be a reporting Financial Institution or a Trustee Documented Trust are required to register with HMRC by 31 December 2025, even if they have no non-UK connections to report.
In Richard Thomas (as executor) v HMRC [2025] TC09716, the First Tier Tribunal (FTT) found that an Income Tax repayment formed part of a deceased taxpayer’s estate for Inheritance Tax (IHT) purposes.
HMRC have published their Employer Bulletin for December 2025. We have summarised the key content for you, which links to our detailed guidance on the topics covered.
