Hello,
Highlights this week include news on gaps in self-employed National Insurance records, two GAAR advisory panel opinions, and an update from HMRC on the cases it is reviewing under the Corporate Criminal Offences rules. We also cover two cases, one of which involves a Home Loan scheme that was effective for Inheritance Tax (IHT) purposes.
Up to 800,000 self-employed taxpayers could be affected by gaps in their National Insurance record that may impact their State Pension entitlement. HMRC have started writing to those potentially affected, offering an opportunity to review and correct missing qualifying years.
The number of live cases being reviewed under the Corporate Criminal Offences (CCO) legislation has decreased slightly in the last six months, while no further charging decisions have been secured.
In Elborne & Ors v HMRC [2026] EWCA Civ 894, the Court of Appeal (CoA) agreed with previous tribunals that an Inheritance Tax (IHT) Home Loan scheme was valid. The value of a settled property within a deceased’s estate could be reduced for IHT purposes by an associated loan note as it was not caught by the relevant anti-avoidance legislation.
In Wensley Stock & Ors v Neal & Anor [2026] EWHC 1823 (Ch), the High Court (HC) found that royalty payments received by a family settlement established by the creator of Thomas the Tank Engine were capital rather than income for trust law purposes. The dispute centred on how royalties arising from an assigned right to receive publishing royalties should be treated within the trust, and whether trust law principles overrode the wording of the settlement.
Hello,
We have another bumper tax update this week, including poor scores for HMRC in the Charter Stakeholder Group’s annual report, with HMRC’s responsiveness receiving the lowest score of all charter standards for the third consecutive year. We also look at HMRC’s July Agent Update and several consultations, including one exploring the tax treatment of predevelopment costs.
The government is consulting on the tax treatment of predevelopment costs. The consultation seeks views and evidence from stakeholders on the types of costs incurred, their tax treatment under the current rules, and the impact this has on investment decisions.
HMRC have published their Agent Update for July 2026. We have summarised the key content, including the phased introduction of mandatory payrolling of Benefits In Kind (BIKs), changes to the taxation of carried interest and voluntary National Insurance Contributions (NICs), the launch of the Advance Tax Certainty Service, Making Tax Digital (MTD) developments, and a range of compliance deadlines and agent service updates.
HMRC have launched a consultation on 'Simplifying treaty relief from withholding tax on interest paid overseas'. Proposals include creating a new administrative process to make it easier and quicker for UK borrowers to obtain double tax treaty relief from withholding tax on overseas interest payments.
The government has published a response to its consultation 'Simplifying the taxation of offshore interest.' It confirms that while stakeholders broadly support efforts to simplify the rules, there are mixed views on moving to a calendar-year basis for taxing offshore interest. Further work will be undertaken before any legislative changes are made.
