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R (Greyhound Board of Great Britain Ltd) v Welsh Ministers [2026] EWHC 670 (Admin) What are the practical implications of this case? The ruling reinforces the constitutional divide between the courts and the legislature. It explains that the scheme and framework of the Government of Wales Act 2006 (GWA 2006) embody that separation of powers, and that any judicial attempt to recognise and enforce a common law obligation on Welsh Ministers to consult prior to introducing legislation in the Senedd would trespass upon that boundary. This is not a departure from established principle; case law has already upheld comparable rules for lawmakers in Scotland and at Westminster. However, this is the first express confirmation of the position for Welsh lawmakers, and the first time this dimension of the GWA 2006 has been analysed in such depth. The court examined earlier
The solution arrived through the United Nations Compensation Commission (UNCC), a quasi‑judicial body handling mass claims, created under UN Security Council Resolution 687. By addressing environmental harm—most notably via its ‘F4’ claim class—the UNCC set a seminal benchmark shaping how international law and contemporary arbitral panels allocate financial responsibility for wartime ecological devastation. With present-day wars in areas such as Eastern Europe and the Middle East bringing dam breaches, strikes on chemical facilities, and the burning of farmland, the UNCC’s legacy endures as an essential reference point for states, global investors, and companies engaged in post‑conflict arbitration. The F4 claims: Quantifying the unquantifiable Prior to the 1990s, mechanisms in international law for war reparations overwhelmingly favoured property loss, foregone earnings, and bodily injury. The natural world was commonly treated as a mute, non-compensable victim of armed hostilities...
Understanding the farming business as a business Many farms still use long-standing structures that arose by habit, not strategy. Sole traders, informal partnerships and outdated partnership deeds are common. While once effective, such setups can cause major issues around succession, tax planning and involving the next generation. A corporate team can take a fresh, business-led view of the farm, asking: Who owns the land and other critical assets? Who manages daily operations? Who carries the risk and who enjoys the return? What is the enduring plan for succession? From this review, the team can confirm whether the current setup is fit for purpose or if an alternative — for example an updated partnership agreement, a company, a limited liability partnership, or a blended model — would better meet the family’s aims. Tax efficiency through joined-up advice Tax sits at the centre of most
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According to the Office for Budget Responsibility’s ( OBR) forecast, HMRC will issue refunds during the 2024–25 tax year. These repayments stem from amounts the government was obliged to collect after the European Commission had first determined that the exemption constituted unlawful state aid. The Court of Justice held that the UK did not breach EU law by granting reliefs to television broadcaster ITV Plc, media group Pearson Plc, and financial firm London Stock Exchange Group Ltd. Its September 2024 judgment overturned the General Court’s 2022 ruling, which had endorsed the Commission’s initial state aid decision. ‘ We have revised......
R (oao Midlands Partnership University NHS Foundation Trust) v HMRC [2024] UKUT 334 ( TCC) Under the Health and Social Care Act 2012 and the Local Authorities ( Public Health Functions and Entry to Premises by Local Healthwatch Representatives) Regulations 2013, SI 2013/315, local authorities carry statutory obligations to secure specified health services, and may procure their delivery through competitive tendering. The Trust won contracts to deliver such services for local authorities, including some beyond its own geographical footprint. Those services were provided without charge to users and funded from public monies. The central question was whether supplying these services to local authorities amounted, as the Trust contended, to a non-business activity undertaken in its capacity as a public authority, or, as HMRC maintained, to a business activity undertaken other than as a public authority. Assessing the contractual framework, the UT concluded that each...
Background and context On 30 October, alongside the Autumn 2024 Budget, the incoming Labour administration unveiled a Corporate Tax Roadmap ( Roadmap), outlining how it intends to shape the UK corporate tax landscape across the parliamentary term (up to five years). Commentary has focused on the breadth of the Autumn Budget measures — notable rises in taxation, borrowing and expenditure pledges — and the Roadmap should be viewed against that backdrop. Ministers have likewise stated a desire to lift private sector investment in the UK to support economic expansion. The Roadmap’s declared aim is to deliver stability, certainty and predictability within corporate taxation, thereby giving businesses the confidence to commit to long-term investments the government sees as vital to its growth plan. It covers core elements of corporation tax — rates, the tax base and principal allowances — alongside strategic direction and...
Syngenta Holdings Ltd v HMRC [2024] UKFTT 998 ( TC) The backdrop was that SHL purchased all of the issued share capital of its sister company, Syngenta Ltd ( SL), from its direct parent, Syngenta Alpha BV ( SABV). As consideration, SHL allotted shares and made a cash payment to SABV. The US$950m cash component of that consideration was financed through the loan at issue, pitching the leverage at what the group, realistically, believed HMRC would ultimately allow. The creditor was a Dutch group treasury entity. HMRC contended that the architects of the structure appreciated that the overriding purpose for their work was to secure non-trading loan relationship ( NTLR) debits under the loan relationship regime, which SHL surrendered to UK group companies to cut their corporation tax liabilities......
FB 2025 has now been released, accompanied by explanatory notes. It received its first reading on 6 November 2024 and will continue its passage through Parliament. The Bill runs to 280 pages, containing 86 clauses and 13 Schedules. Clause 86 provides that the short title is the Finance Act 2025. Any clause and Schedule references in this analysis use the numbering as at introduction. Draft provisions for three measures in FB 2025 were initially issued on Legislation Day ( L Day) on 29 July 2024. These comprised: the abolition of the furnished holiday lettings regime (as announced in the Spring Budget 2024) the introduction of an anti-arbitrage limit on the transitional country-by-country reporting safe harbour within the UK’s Pillar Two rules the removal of the value added tax ( VAT) exemption for private school fees FB 2025 also features measures first...
In this issue: Budgets and Finance Bills Companies and corporation tax Real estate tax International VAT Taxes management and litigation Employment taxes Lex Talk®Tax: a Lexis®Nexis community Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Budgets and Finance Bills Finance Bill 2024–25 published Finance Bill 2024–25 was issued on 7 November 2024. Also known as the Autumn Finance Bill 2024, it was presented in the House of Commons and received its first reading on 6 November 2024. We will release commentary on the Bill’s provisions together with a tracker following its journey through Parliament. See: Finance Bill 2024–25. Autumn Budget 2024 As noted in last week’s Tax weekly highlights, after the Autumn Budget on Wednesday 30 October, we delivered overnight coverage of the principal business tax measures in the...
FTT rejects HMRC’s interpretation of contracted out expenditure in R& D rules ( Collins Construction Ltd v HMRC) Collins Construction Ltd v HMRC [2024] UKFTT 951 ( TC) The claimant operated as a building company, handling both the design and the delivery of refurbishment projects for other businesses. Its invitations to tender did not expressly call for any research and development activity; nevertheless, from time to time the firm had to engineer original fixes for particular technical challenges. A case in point was a reverberation issue, for which it devised a bespoke approach. There was no disagreement that this spend—and comparable costs—were incurred on R& D. The debate concerned whether relief was prohibited because the expenditure had been subsidised. The Corporation Tax Act 2009 characterises expenditure as subsidised where the cost is borne, directly or indirectly, by a person other than the company making the...
Procurement International Ltd v HMRC [2024] UKFTT 949 ( TC) The Appellant supplied goods to reward programme operators ( RPOs), who then made onward supplies of those goods to employers. The RPOs ran online platforms enabling eligible recipients—employees and/or customers of those employers—to choose a reward comprising goods. After a recipient made a selection, the RPO submitted an order to the Appellant. The Appellant subsequently organised the movement of the goods from its Great Britain warehouse, using shippers with whom it held contracts, to the recipient’s address. The dispute related to goods provided to UK VAT-registered RPOs and (a) delivered to recipients situated outside the EU before 1 January 2021, and (b) delivered to recipients located outside the UK after 31 December 2020. HMRC accepted that the goods had been exported but did not accept that the Appellant was the...
Murphy and another v HMRC [2024] UKFTT 947 ( TC) The appellants, Mr and Mrs Murphy, purchased a property for £277,000 using a joint mortgage. On the same day the sale contract was signed, they entered a further agreement under which Mr Murphy committed to transfer to Mrs Murphy all but 1% of his 57% interest in the property, with that transfer taking place under the sale contract. The arrangement aimed to trigger the sub-sale provisions in section 45 of the Finance Act 2003, so that for SDLT the chargeable consideration would be limited to what Mrs Murphy paid under the sale contract for her 43% share, namely £119,100. As this amount was below the SDLT threshold, their SDLT1 return reported no SDLT payable. The first question before the FTT was whether HMRC’s discovery assessment was valid. HMRC’s interest was prompted because the...
In this issue Budgets and Finance Bills Business structures VAT Taxes management and litigation Real estate taxes Anti-avoidance Employment Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Autumn Budget 2024 On Wednesday 30 October 2024, Chancellor of the Exchequer Rachel Reeves presented Labour’s first Budget in 14 years, the inaugural Budget delivered by a woman. Headline measures included: Employer National Insurance contributions rising from 13.8% to 15% from 6 April 2025, alongside a cut to the secondary threshold to £5,000 per annum. Capital gains tax on carried interest increasing to 32% from 6 April 2025, with a reworked carried interest regime to be brought within the income tax framework from 6 April 2026. CGT rates for disposals qualifying for business asset...
Inherited pension pots will fall within inheritance tax from April 2027, Chancellor Rachel Reeves confirmed in the Autumn Budget on 30 October 2024. She said the move corrects a distortion that has seen pensions deployed as a tax-planning tool to pass on wealth, rather than fulfilling their core aim of supporting retirement. This reform sits among a suite of measures from the Labour government intended to address the previously announced £22 billion shortfall in public sector finances. As set out in the Autumn Budget Statement, HM Treasury confirmed that, from 6 April 2027, unused pension pots and death benefits payable from pension arrangements will be counted within an individual’s estate for inheritance tax ( IHT) calculations. In addition, pension scheme administrators will be responsible for reporting and settling any IHT owed on unspent pension monies and death benefits accordingly under these new...
Autumn Budget 2024: initial reaction from the market. Follow this link to watch the video:...
The Chancellor of the Exchequer, Rachel Reeves, delivered the government’s Autumn Budget on 30 October 2024 Keenly awaited and watched, this was the first Budget from a Labour administration in fourteen years, and the first ever presented by a woman Chancellor. Many headline measures for Private Clients had been trailed in one form or another, and several of the changes—such as the Capital Gains Tax reforms—were not as draconian as many had feared, proving less severe than anticipated. It was definitely a Labour Budget, unmistakably Labour in flavour, with the Chancellor honouring election pledges not to raise income tax or National Insurance for ‘working people’, and instead securing the £40bn of tax rises by lifting employers’ National Insurance, narrowing the scope of IHT agricultural and business property reliefs, increasing CGT rates, reforming the taxation of carried interest, changing the rules for non‑ UK...
Abbeyford Caravan Company ( Scotland) Ltd v HMRC [2024] UKFTT 928 ( TC) The appellant traded in caravans supplied with removable contents, quoting a single, bundled price for each unit and its contents. Provided certain conditions are met, a caravan sale can fall within either the reduced VAT rate or the zero rate under the Value Added Tax Act 1994: the reduced rate in Group 12 of Schedule 7A to VATA 1994, or the zero rate in VATA 1994, Sch 8, Grp 9 Both VATA 1994, Sch 7A, Grp 12 and VATA 1994, Sch 8, Grp 9 exclude removable contents sold with caravans. This means those contents are, in general, standard-rated, even where the caravan itself qualifies for the reduced or zero rate. On resale, the appellant had historically mirrored the manufacturers’ allocation, assigning the same proportion of its selling price to removable contents as the split used when...
GCH Corporation Ltd and others v HMRC [2024] UKFTT 922 ( TC) Gregory Hutchings ( GH), who held senior posts at Tomkins plc ( Tomkins) until 2000, served as trustee of three family trusts (the Trusts). The Trusts and GCH Corporation Ltd (the Company), which GH controlled, amassed sizeable holdings in Tomkins. Once a potential takeover of Tomkins was announced, GH sought advice on disposing of the Trusts’ and the Company’s shares and chose to incorporate GCH Active LLP (the LLP). The LLP carried out limited activity; nevertheless, it acquired five unrelated shareholdings (two sold shortly afterwards), funded by what was later recorded as a £200,000 loan from GH. When the takeover of Tomkins completed, the Trusts exchanged all their Tomkins shares, and the Company part of its holding, for loan notes issued by the purchaser (the Notes). Thereafter, the Trusts and the...
Lefort v HMRC [2024] UKFTT 926 ( TC) The taxpayer, an airline pilot employed by Virgin Airlines, held a self‑invested pension plan ( SIPP) to which both he and Virgin contributed. He left the business in February 2014, making a final payment into the plan and obtaining a Fixed Protection 2014 certificate at that time. Virgin’s own final contribution was not made until May 2014, falling after the cut‑off prescribed by the fixed protection regulations. As a consequence, HMRC exercised their power to revoke the certificate, and the taxpayer appealed against that decision......
Hill and another v Revenue and Customs Commissioners [2024] UKFTT 844 ( TC) What are the practical implications of this case? The tribunal found the taxpayers’ evidence lacking, even though they seemingly depended entirely on professional advice. In particular, it concluded that, when given vague and uncertain guidance by their advisers, the taxpayers could not simply remain passive; further action was required to demonstrate a reasonable excuse that would prevent liability for failing to comply with an Information Notice, or alternatively to lessen the penalty imposed. In delivering the judgment, the judge set out, from an objective standpoint, a series of conclusions describing how a reasonable and prudent taxpayer should have acted on the facts. The message was that passivity in the face of unclear professional input falls short of what a diligent taxpayer should do, and that only active engagement could support...
In this issue Budgets and Finance Bills International Taxes management and litigation Companies and corporation tax Anti-avoidance Employment taxes Individuals and income tax Daily and weekly news alerts New and updated content Dates for your diary Trackers Useful information Budgets and Finance Bills Autumn Budget 2024 The Chancellor of the Exchequer, Rachel Reeves, will present the Autumn Budget on Wednesday 30 October 2024. As is our custom, we will produce overnight analysis of the principal business tax measures announced, which will be published on the morning of Thursday 31 October 2024. International Jersey adopts legislation to implement Pillar 2 from 2025 Jersey has enacted legislation to introduce a Pillar 2 Income Inclusion Rule and a multinational corporate income tax from 2025, honouring Jersey’s commitment to implement the OECD’s global minimum tax framework for large in-scope...
National Insurance ( NI) Contribution pension relief Hymans Robertson warned that the rumoured cut or scrapping of National Insurance ( NI) Contribution pension relief would deal a significant blow to employers—especially those seeking to lift retirement outcomes for staff by contributing beyond the statutory minimum. Removing the relief would leave a company paying an extra £442 each year on a 5% contribution for an employee earning £32,000 annually, it said. Hannah English, head of defined contribution consulting at Hymans Robertson, cautioned that proposals expected in the forthcoming Autumn budget could have far-reaching consequences for businesses. Our worry is the potential effect where today’s NI saving is used to boost pension contributions, English added. The implications for employers would be vast, Hymans stressed......
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When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...
This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...
Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
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