Benjamin Wonnacott

2 months ago | taxjournal.com | David Whiscombe |Benjamin Wonnacott

Various newspapers have reported comments of Rachel Reeves at Davos that she is considering tweaks to the Temporary Repatriation Facility (TRF). The TRF (in case you didn’t know) is an ability for non-doms to clean up past income and gains that have benefitted from the remittance basis by paying a flat rate of 12% in 2025/26 or 2026/27 or 15% in 2027/28. Once cleaned, it can then be remitted to the UK without triggering any further tax charges on that remittance.

2 months ago | taxjournal.com | David Whiscombe |Benjamin Wonnacott

In Hoopla Animation Ltd (formerly known as Daisy Boo and Monkey Too Ltd) v HMRC [2025] UKUT 28 (TCC) (23 January) the Upper Tribunal (UT) considered the taxpayer’s appeal against the FTT decision that HMRC were right to refuse authorisation to the taxpayer to issue EIS compliance certificates on the basis there existed ‘disqualifying arrangements’ for the purposes of ITA 2007 s 178A.

2 months ago | taxjournal.com | David Whiscombe |Benjamin Wonnacott

The Public Bill Committee was scheduled to begin its scrutiny of Finance Bill 2025 on Tuesday 28 January 2025 considering a raft of Government amendments which had been put forward in two batches. The first tranche issued on 19 December 2024 covered Schedule 4 (Pillar Two) and also added a clause on vehicle excise duty which had unintentionally been omitted from the original version of the Bill. The Government’s issued on 23 January covers the following.

2 months ago | taxjournal.com | David Whiscombe |Benjamin Wonnacott

The Welsh Government has confirmed that it will end charitable business rates relief for some fee-charging schools with effect from 1 April 2025 subject to approval by the Senedd. The policy decision here is to bring independent schools with charitable status into line with other independent schools in Wales for non-domestic rates purposes.

2 months ago | taxjournal.com | David Whiscombe |Benjamin Wonnacott

The Government launched its further independent review of the loan charge on 23 January announcing in a Written Ministerial Statement that Ray McCann former CIOT President would lead the review. James Murray Exchequer Secretary to the Treasury has asked for a final report and recommendations ‘by summer 2025’ (with the timing of publication to be decided by Mr Murray). The Government is then expected to publish its response to the review by Autumn Budget 2025.