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Dec 4, 2024 | 
taxjournal.com | Gary Barnett |Heather Self |Tanja Velling
In K (oao Midlands Partnership University NHS Foundation Trust) v HMRC [2024] UKUT 334 the UT held that healthcare services provided by an NHS trust under a contract with a local authority amounted to supplies for VAT purposes. The UT rejected the trust’s argument that it was necessary to look beyond the contractual arrangements at the wider reality and public health provision context in which the contract subsisted.
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Dec 4, 2024 | 
taxjournal.com | Jenny Doak |Akash V. Mehta |Heather Self |Tanja Velling
Before looking at global trends it is worth noting that the UK introduced non-resident taxation on chargeable gains back in 1973 in the form of what is now TCGA 1992 s 276. This provides that non-residents which otherwise do not have a permanent establishment in the UK are subject to chargeable gains on disposals of ‘exploration or exploitation assets’ and ‘exploration or exploitation rights’.
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Dec 4, 2024 | 
taxjournal.com | Stuart Maggs |Mike Lane |Heather Self |Andrew Park
As the Chancellor came to the latter stages of her Autumn Budget 2024 speech she announced: ‘From April 2026 the first £1m of combined business and agricultural assets will continue to attract no inheritance tax at all but for assets over £1m inheritance tax will apply with 50% relief at an effective rate of 20%.
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Nov 27, 2024 | 
taxjournal.com | Victoria Braid |Heather Self |Andrew Park |Peter Vaines
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Nov 27, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
In HMRC v The Taxpayer and others [2024] UKUT 364 (TCC) (19 November) the UT rejected the taxpayer’s application for anonymity as no clear and cogent evidence justifying exclusion from the principles of open justice had been demonstrated. Unless appeal is made to the Court Appeal (CA) the decision should be republished without anonymisation on 11 December.
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Nov 27, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
Transfer pricing experts are used to grappling with some tricky valuation questions when it comes to intellectual property rights.
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Nov 27, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
During a prime time news bulletin last week about the farmers’ protest in Westminster, there was a ‘fact check’ section in which the presenter gave examples of how the proposed agricultural property relief rules would work in practice. One example was based on a single farmer dying with an estate worth £2.2m, the entirety of which qualified for agricultural property relief and was left to a child. The tax calculation in that example was in fact wrong.
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Nov 26, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
The CIOT has responded to the draft legislation published at Autumn Budget 2024 which when enacted will make changes to the tax regime for employee-ownership trusts (EOTs) with effect from 30 October 2024. The EOTs provisions are set out in Sch 6 to Finance Bill 2025.
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Nov 26, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
The Aggregates Tax and Devolved Taxes Administration (Scotland) Act 2024 received royal assent on 12 November 2024. The Act introduces the new Scottish aggregates tax which is expected to replace aggregates levy in Scotland from 1 April 2026. Part 1 of the Act defines Scottish aggregates tax and its key concepts and explains how the tax should be calculated and gives the Scottish ministers the power to set the rate of tax.
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Nov 26, 2024 | 
taxjournal.com | Mike Lane |Heather Self |Andrew Park
The Land Transaction Tax (Relief for Special Tax Sites) (Wales) Regulations SI 2024/1193 provide for relief from the Welsh land transaction tax for qualifying transactions of land in designated special tax sites in Wales – broadly mirroring the equivalent relief from SDLT that is available for special tax sites in England. The first special tax sites in Wales are designated with effect from 26 November 2024 and are located within the Celtic Freeport areas.
