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3 weeks ago | 
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
In T Eyre and others v HMRC[2025] UKFTT 566 (TC)(22 May) the First-tier Tribunal (FTT) held that the appellants were not entitled to entrepreneurs’ relief on disposals of shares in a property company. Although the company was preparing to carry on a trade its activities during the relevant period included to a substantial extent non-trading activities. As such it was not a ‘trading company’ for the purposes of the relief.
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3 weeks ago | 
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
The Financial Times reports (2 June) that ‘Keir Starmer has rejected calls from senior Labour figures to fill a growing fiscal hole with big tax rises, warning “we can’t tax our way to growth”.’ Starmer is correct. We can’t tax our way to growth. But we can ‘tax reform’ our way to growth. Some ideas:Corporation tax simplification. The UK corporate tax system is currently less competitive than Italy or Greece, never mind Sweden and Denmark. Eliminate crazy high income tax marginal rates.
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3 weeks ago | 
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
The UK tax landscape is undergoing one of its most significant shifts in decades. Since April 2025, the concept of domicile – long a cornerstone of the UK’s tax system – has effectively been abolished looking forward for tax purposes. In its place, a new regime based on residence has taken over, reshaping how rules on foreign income, gains and IHT are applied to individuals with international ties. But does this mean domicile is truly dead? Not quite.
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3 weeks ago | 
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
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3 weeks ago | 
taxjournal.com | Dan Neidle |Peter Vaines |Greg Smythe |Heather Self
In Walkers Snack Foods Ltd v HMRC [2025] UKUT 155 (TCC) (23 May) the UT agreed with the FTT and HMRC that a product known as Sensations is a similar product to potato crisps and is made from the potato because the potato includes potato granules. VATA 1994 Sch 8 Group 1 provides for the zero rate of VAT to apply to food but refers to excepted items. Excepted item 5 includes ‘potato crisps’ and ‘similar products made from the potato or from potato flour or from potato starch’.
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3 weeks ago | 
taxjournal.com | Peter Vaines |Dan Neidle |Greg Smythe |Heather Self
One of the many uncertainties with Business Asset Disposal Relief (the relief formerly known as something else) is the definition of a trading company in TCGA 1992 s 165A(3) as: ‘a company carrying on trading activities whose activities do not include to a substantial extent activities other than trading activities’. Section 165A(4) goes on to explain what trading activities mean, but there is no further assistance about what is meant by ‘to a substantial extent’.
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1 month ago | 
taxjournal.com | Heather Self |Chris Etherington |Veronica McMahon
As someone who is approaching State Pension age, the debate over the Winter Fuel Payment (WFP) has had a clear resonance for me. But I fear that we may be ending up in yet another muddled tax policy position. The WFP was introduced in 1997, and was originally £20 (£50 for those on means-tested benefits).
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1 month ago | 
taxjournal.com | Emily Au |Heather Self |Chris Etherington |Veronica McMahon
Q: Why should you never play hide-and-seek with tax litigators? A: Because they’re experts at finding the loopholes and the grey spaces!Readers of Tax Journal may be relieved to know that this joke was not the authors’ original wit but rather generated by AI. Humour may not be its strong suit but AI innovations hold great promise and risk for tax administration and disputes.
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1 month ago | 
taxjournal.com | Chris Etherington |Heather Self |Veronica McMahon
One of the consequences of the Autumn 2024 Budget announcements on IHT is that many families are now considering passing assets on to the next generation sooner than they might have otherwise planned. This will commonly involve parents making gifts to their children, and in many of these scenarios, there are concerns about how to make such gifts whilst maintaining some control over these assets during the parents’ lifetime.
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1 month ago | 
taxjournal.com | Naomi Lawton |Heather Self |Chris Etherington |Veronica McMahon
On 28 April 2025 the UK Government published two documents relating to the reform of its stamp taxes regime: Modernisation of the Stamp Taxes on Shares Framework- Summary of responses (the consultation response document) further to the 2023 consultation on stamp taxes on shares modernisation; and Modernisation of the Stamp Taxes on Shares Framework: 1.5% charge (the consultation on the 1.5% charge).
