Tax

Welcome to the August 2024 edition of the UK Tax Digest, featuring a roundup of various recent tax developments. Following the announcement on 22nd May that the UK would hold a general election on 4th July, we had been closely monitoring the parties’ stances on tax policy, as outlined in our June blog on Tax and the General Election 2024: The Manifestos. Following Labour’s victory on 4th July, we are now awaiting a raft of changes to UK tax policy and legislation as Labour’s manifesto pledges come to fruition.

In her address to Parliament on 29th July, Rachel Reeves, the new Chancellor of the Exchequer, announced that she will deliver her first Budget on Wednesday, 30th October. In conjunction with the Chancellor’s speech, the Government also published various pieces of draft legislation and technical documents, including (amongst others) a call for evidence on the tax treatment of carried interest and a policy paper on changes to the energy profits levy. You can read more about these announcements here.

In other news, the January edition of the Digest noted our anticipation of a run of noteworthy cases in the courts this year, and a number of decisions have indeed been handed down over the course of the past few months. These include Court of Appeal decisions on the unallowable purpose rule for loan relationships, in a number of cases, including JTI Acquisition Company (2011) Limited v HMRC and Kwik-Fit Group Ltd and others v HMRC, and an Upper Tribunal decision in HMRC v Burlington Loan Management DAC regarding anti-abuse provisions for double tax treaty relief. We also considered the question of “when is an option not an option?” in our coverage of the First-Tier Tax Tribunal’s decision in M Krishnamohan and another v HMRC. 

On the international tax front, our February blog summarised the latest changes to the EU’s so-called “blacklist” of jurisdictions that are non-cooperative for tax purposes; the next update to the blacklist is expected in October 2024.

As we see an uptick in groups undergoing restructurings, we have published a joint article with Loyens & Loeff setting out some of the tax issues which can arise, entitled “Debt restructurings: Lux, Dutch and UK tax perspectives”, which first appeared in Corporate Rescue and Insolvency Vol 17.2 April 2024. Adding to our coverage of various issues pertaining to insolvency and debt restructuring, we have also shared our insights and updates on topics including VAT Groups and Insolvency, Tax Groups and Insolvency and the UK Corporate Interest Restriction and the Debt Restructuring Exemption.

As we move into August and September, we will no doubt continue to see further changes to the UK tax landscape, culminating in the Autumn Budget on 30th October. Enjoy the rest of the summer, and stay tuned in to the Weil Tax Blog for all our latest thinking.