In this podcast, Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decision in Blackfriars Hotel applying an anti-avoidance provision in the loss relief regime to a loss-refreshing transaction reminiscent of the Kwik-Fit unallowable purpose case.

They also discuss the First-tier Tribunal’s decision in Grint on the sale of occupational income rules (which had been used by HMRC as an alternative argument in the BlueCrest, HFFX and BCG partnership remuneration cases) and the Court of Appeal’s decision in Refinitiv, a judicial review case concerning the compatibility of diverted profits tax notices with a prior advance pricing agreement.

They are then joined by Tax Associate Kasim Mehmood for a discussion of the Supreme Court’s approach to interpreting tax legislation in Cobalt Data Centre and changes to HMRC’s capital gains manual in respect of the reorganisation rules.

The podcast also covers PISCES, a proposed new type of regulated trading platform for private shares, and what 2025 might bring in terms of UK, EU and US tax developments, including (in case of the UK) various consultations on changes to the transfer pricing rules as well as potential enquiry activity in this area.

In this special episode of our Tax News podcast, Zoe Andrews and Tanja Velling asked Arvind Ravichandran, Tax Partner at Cravath, Swaine & Moore LLP, what U.S. tax policy may look like during a second Trump Administration.

During the episode, we cover:

• The significance of the Republican Party achieving a “trifecta” in the November 2024 elections.
• How tax legislation can be passed by simple majority vote through the Budget Reconciliation process.
• What policy proposals could be on the table and how you can look out for clues as the incoming Administration’s policies develop.

Listen to the podcast to learn more about what might happen next on U.S. tax policy.

In this podcast, Catrin Young, Senior Professional Support Lawyer in the Pensions Team, joins Zoe Andrews and Tanja Velling to discuss the government’s policy decision at the Autumn Budget to bring unused pension savings and death benefits into the scope of inheritance tax (with the charge to be administered by pension trustees), and HMRC’s recent clarification that the authorised surplus payment charge payable by the trustees of a defined benefits scheme when returning a surplus to an employer is to be calculated by reference to the gross amount of the surplus (rather than the amount received by the employer).

Zoe and Tanja also discuss the increase in late payment interest from April 2025, two updates to HMRC guidance, the UK expert panel’s report on a potential corporate re-domiciliation regime and certain international developments.

The podcast further covers three UK cases: the First-tier Tribunal’s decision in Syngenta, denying interest deductions for a loan created in an intra-group reorganisation under the unallowable purpose rule in section 441 of the Corporation Tax Act 2009, and the Upper Tribunal’s decisions in Gould on the tax point for an interim dividend where two shareholders were paid around eight months apart, and in Panayi on conforming interpretation.