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UK Care No 1 Ltd v HMRC [2024] UKFTT 542 (TC) The FTT examined the operation of the ‘imported losses’ restriction contained in CTA 2009, s 327. Under that code, relief for a loss arising on a loan relationship is denied to the extent the loss is properly referable to a period during which the company attempting to bring it into account would not have been chargeable to corporation tax on any profits from that same loan relationship. The appellant, which was tax resident in Guernsey, had issued certain loan notes that were secured over the BUPA group’s UK care home undertaking. In 2016, BUPA sought to sell a number of care homes that constituted part of the security package supporting the notes. To enable those transactions to proceed, BUPA acquired the appellant, with the result that the appellant became UK tax resident, following which the notes were redeemed by the appellant itself. The loan notes incorporated a ‘Spens’ (or ‘make whole’) provision; broadly, this meant that on an...
In this issue: UK, EU and international regulators and bodies Authorisations, approvals and oversight Prudential obligations Financial crime and sanctions Consumer protection Complaints, redress and claims management Investigations, enforcement and disciplinary matters Sustainable finance and ESG Banks and mutuals Investment funds and asset management Investment funds and asset management Insurance regulation FSMA-regulated pensions activity Regulation of AI in FS LexTalk®Financial Services: a Lexis®Nexis community Financial Services Enforcement Database Daily and weekly news alerts Intraday news alerts New and updated content Dates for your diary Latest Q&A UK, EU and international regulators and bodies Commission tables €193.26bn EU budget for 2026 to drive key priorities The European Commission has tabled its draft 2026 EU budget, fixing overall appropriations at €193.26bn, alongside an estimated €105.32bn in disbursements through NextGenerationEU. Set against ongoing geopolitical instability, the plan is designed to underpin core strategic aims, including...
In this issue: Key developments UK immigration control: how it works Sponsored work Challenging immigration decisions and enforcement Preventing illegal working International Daily and weekly news alerts New and updated content Latest Q&A Key developments Future developments—Immigration calendar Please note that our Immigration calendar outlines key forthcoming developments relevant to business immigration advisers. UK immigration control: how it works Replacement BRP service closed on 26 September 2024 and no more BRPs issued from 31 October On 26 September 2024, the Home Office updated a range of guidance documents and materials to confirm the withdrawal of the replacement Biometric Residence Permit (BRP) service on that day, as part of the ongoing transition to a fully digital immigration status from 1 January 2025. In a related, linked development, the Home Office emailed stakeholders the same day to state that no new BRPs will be issued at all from 31 October 2024...
Background In December 2015, the Migration Advisory Committee (MAC)—an independent arm’s length public body advising government on immigration—issued a comprehensive assessment of Tier 2 policy. At that point, Tier 2 encompassed the skilled worker pathways. Among its proposals, the MAC suggested an Immigration Skills Charge (ISC) to encourage UK employers to ‘reduce their reliance’ on migrant labour and channel resources into training and upskilling domestic workers. The Committee examined this at the government’s specific request, and provision for an ISC already appeared in the Immigration Bill then before Parliament, which later became the Immigration Act 2016 (IA 2016). The MAC advised that the levy should apply to all sponsoring employers hiring via Tier 2 (General) and (Intra-Company Transfer) (ICT) routes, save for cases where individuals were sponsored under the Graduate Trainee and the (then still operating) Skills Transfer ICT sub-categories. On 24 March 2016, the government issued its response to the MAC’s review, agreeing to most of the Committee’s recommendations. The response broadly endorsed the MAC’s overall approach and...
Forthcoming developments: In December 2025, the Migration Advisory Committee released its review of salary requirements for work visas, advising that the general and occupation‑specific salary thresholds in the Senior or Specialist route should be pegged to the median earnings of eligible occupations. For the Graduate Trainee route, the Committee proposes a single salary threshold of £33,400, aligned with the Skilled Worker new entrant rate, and calls for the removal of occupation‑specific rates. See: LNB News 17/12/2025 33. Senior or Specialist Worker and Graduate Trainee are Global Business Mobility routes that, from 11 April 2022, replaced the Intra‑Company Transfer and Intra‑Company Graduate Trainee routes respectively. The Senior or Specialist Worker route permits organisations with overseas linked entities to move established employees to their UK offices to perform skilled roles. For sponsorship fee purposes, it is treated as a Worker route, and partners in business structures such as limited liability partnerships (LLPs) are considered employees. The route is contained in the Immigration Rules, Appendix Global Business Mobility—Senior or Specialist Worker....
This analysis covers the main changes to the Immigration Rules (the Rules) set out in HC 667 that are likely to be of most interest to business immigration advisers HC 667 was issued on 3 November 2016, accompanied by an Explanatory Memorandum (EM). The Statement of Changes had been long heralded, after the government signalled on 24 March 2016 that it would bring in its first set of Tier 2 reforms in ‘Autumn 2016’, following consideration of the Migration Advisory Committee’s reports on its review of Tier 2 and its partial review of the shortage occupation list: Review of nursing. Through HC 667 these Tier 2 measures are enacted, alongside a suite of technical amendments across multiple categories, notably substantive revisions to the Rules on the validity of applications for leave to remain, overstaying, and evidential flexibility within Points-Based System (PBS) applications. In addition, from 1 May 2017 a new A2 English language requirement is introduced for applicants who, having previously received an initial grant of leave to enter...