2022–23—Spring Statement, Budget and Finance Bill

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Finance Bill 2025 update: Public Bill Committee to begin in January

The Public Bill Committee is expected to begin scrutiny of the Finance Bill on 28 January 2025. Comments on the Bill are invited before then, and revised explanatory notes have been issued to cover the Government’s proposed Pillar 2 amendments.

FTT considers meaning of interest and decides that an element of redress payments constituted interest (NHS Mid & South Essex ICB and others v HMRC)

Tax analysis: In NHS Mid & South Essex ICB and others, the First-tier Tax Tribunal (FTT) decided that an element of the NHS continuing healthcare (CHC) redress payments constituted interest for the purposes of section 874 of the Income Tax Act 2007 (ITA 2007) and, furthermore, that the interest constituted yearly interest or was treated as yearly interest under ITA 2007, s 874(5A) since the interest was payable to individuals in respect of compensation.

Tax weekly highlights—19 December 2024

This week's edition of Tax weekly highlights includes: (1) the House of Commons committee debating (but not amending) clauses of the Finance Bill 2025, (2) the NICs Bill passing the House of Commons stages without amendment, and (3) the Spring Forecast to be published on 26 March 2025.

FTT applies carried-forward losses anti-avoidance rule (Blackfriars v HMRC)

Tax analysis: In Blackfriars Hotel (UK) Holdings Ltd, the First-tier Tax Tribunal (FTT) held that the anti-avoidance ‘loss refresh’ provisions of Part 14B of the Corporation Tax Act 2010 (CTA 2010) applied to disallow relief for pre-April 2017 carried forward loan relationship deficits against profits arising from tax arrangements entered into by the company.

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Scotland—the process for applying for sequestration

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Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid
Scotland—the process for applying for sequestration

Scotland—the process for applying for sequestration

Scotland—the process for applying for sequestrationSequestration in Scotland is the legal process by which an insolvent debtor’s estate is gathered in, realised and then distributed among their creditors by a trustee appointed for that purpose. The process requires that a formal award of

Micklefield clauses

Micklefield clauses

Micklefield clausesWhat is a Micklefield clause?It is common for employee share plans to provide that, on termination of employment (or when an employee is given or receives notice of termination of employment), subsisting share awards will be forfeited and subsisting share options will lapse.It is

Early leavers—preservation

Early leavers—preservation

Early leavers—preservationFORTHCOMING DEVELOPMENT: Section 10 of the Finance Act 2022 will increase the normal minimum pension age (NMPA) from 55 to 57 on 6 April 2028 (save for members of the firefighters, police and armed forces public service pension schemes).The Finance Act 2022 will also give

Late payment penalties—inheritance tax

Late payment penalties—inheritance tax

Late payment penalties—inheritance taxWhile interest often accrues on overdue tax, the late payment of certain taxes may also attract a penalty. For information on the interest accruing on overdue tax, see Practice Notes: IHT—payment deadlines on death—Interest on IHT and Interest on late paid