Tax News

Tax News: July 2026 16.07.2026 27min

The latest edition of Slaughter and May's Tax News podcast (July 2026) is out now, hosted by Zoe Andrews (Head of Tax Knowledge) and Tax associate Amy Motherwell. The podcast covers several developments that may be relevant to you including: Key cases: The Supreme Court's decision in HFFX on the limits of purposive construction and the charge to miscellaneous income; the Upper Tribunal's decision in Barclays Services Corporation upholding the FTT's finding that a US company's UK branch lacked sufficient resources to constitute a fixed establishment for VAT grouping purposes; and the Upper Tribunal's decision in Swiss Centre on when payments qualify for deductions under the loan relationship regime. UK developments: HMRC's consultation on reducing the high effective tax rates faced by UK-resident individual members of US LLCs and other reverse hybrid entities; the surprise consultation on modernising the distributions framework covering share buybacks, demergers, returns of capital and transactions in securities; and HMRC's Transformation Roadmap progress update including new third-party data reporting obligations and plans to improve digital services. International spotlight: The European Commission's tax simplification package comprising a Direct Taxation Omnibus Directive amending six existing EU tax directives and a DAC recast consolidating all administrative cooperation rules into a single instrument — with adoption of the DAC recast potentially achievable by end of 2026.

Tax News: May 2026 21.05.2026 25min

For this month’s edition, Gabrielle Pereira and Alex Dustan join Zoe Andrew to discuss: Supreme Court's Gunfleet Sands decision: A restrictive ruling on capital allowances for predevelopment costs Electricity Generator Levy: Increase from 45% to 55% from July 2026, with voluntary fixed-price contracts Court of Appeal in Burlington : Important clarification of treaty purpose tests, with global implications for the principal purpose test Court of Appeal in MR Currell : The purpose of a payment does not determine its legal character VAT classification of Mega Marshmallows (Innovative Bites ): They're zero-rated food, not confectionery Inbound redomiciliation consultation: Proposals to allow foreign companies to move their place of incorporation to the UK

Tax News: March 2026 19.03.2026 26min

For this month’s edition, Ed Milliner joins Zoe Andrews to discuss three cases: Sintra (CA) – burden of proof in tax penalty appeals, Lycamobile (UT) – VAT on bundle plans (and two perfect quotes about VAT…), and Muller (CA) – how the partnership notional company fiction interacts with the intangible fixed assets rules. The podcast then covers various UK tax developments including: tax adviser registration rollout with proposed delay for in house teams in the financial services industry, NAO report on taxing large businesses, and uncertain Tax Treatment consultation on extending the notification regime – including a possible new trigger where HMRC’s position is not known and there is more than one credible legal interpretation.

Tax News: January 2026 29.01.2026 29min

For this month’s edition, Jamshed Bilimoria joins Zoe Andrews to discuss three cases: Hotel La Tour (Supreme Court judgment on input VAT recovery on deal fees), Tower One St George Wharf (Court of Appeal decision on SDLT and anti‑avoidance) and Font (High Court decision on judicial review in MAP dispute). The podcast then covers aspects of the Autumn Budget and Finance Bill including: mandatory tax adviser registration, SDRT exemption for newly listed companies, reform of transfer pricing, and permanent establishment (PE) rules; and the new corporation tax charge replacing DPT and changes to the share for share exchange rules and the impact on clearances. Jamshed and Zoe go on to explore international developments in two areas: the OECD’s global minimum tax “side‑by‑side package” (including new safe harbours and simplification measures) and the OECD updates on global mobility, including when home‑working may (or may not) create a PE.

Tax News: November 2025 21.11.2025 21min

For this month’s edition, Alex Sim joined Zoe Andrews to discuss three cases of the FTT: Dialog (the tax treatment of break fees), Boulting (purchase of own shares was not a distribution) and Ferrero (the VAT treatment of Nutella biscuits). The podcast then covers HMRC’s campaign on management expenses and HMRC’s policy (set out in Revenue & Customs Brief 6 (2025)) on VAT deduction on insurance intermediary services supplied outside the UK following the FTT’s decision earlier this year in Hastings Insurance. Alex and Zoe go on to explore various international developments including the OECD’s recent APA/MAP awards and France’s proposal to double the rate of its digital services tax.

Tax News: October 2025 09.10.2025 25min

Sarah Osprey joined Zoe Andrews and Tanja Velling to discuss trends in HMRC enquiries and the use of criminal investigation powers in a tax context. The podcast then covers the Supreme Court’s decision in Prudential Assurance on the interaction between the VAT grouping and time of supply rules, and the CJEU’s decision in Arcomet Towercranes that transfer pricing adjustments can trigger VAT liabilities.

Tax News: September 2025 04.09.2025 26min

Sarah Osprey joined Zoe Andrews and Tanja Velling to talk about tax disputes and our exciting new project in this area. The podcast further covers three decisions of the First-tier Tribunal: Currys Retail on the capital gains tax degrouping charge Millennium Cash & Carry, the first case on the so-called “sugar tax” which highlights the limits of statutory construction Motorplus on VAT recovery with the FTT commenting on HMRC’s extraordinary behaviour Zoe and Tanja go on to discuss L-Day materials including draft legislation for inheritance tax on inherited pension and death benefits, HMRC’s increased powers to close in on promoters, and the mandatory registration requirement for tax advisers interacting with HMRC, as well as certain other UK and international tax developments.

Tax News: July 2025 31.07.2025 26min

Zoe Andrews and Tanja Velling discuss the following recent cases: Dolphin Drilling: the Supreme Court’s decision on the meaning of “incidental” should not be read as having wider application beyond the oil contractor regime Haworth (Court of Appeal) applying the place of effect management test to a trust in the context of a “round the world” capital gains tax scheme Marlborough DP (Court of Appeal) on the tax treatment of a remuneration structure involving loans made by a trust and the meaning of “in connection with” in Part 7A of ITEPA Osmond: the Upper Tribunal held that it was an error of law to equate seeking a capital gains tax relief with having a main purpose of obtaining an income tax advantage Eastern Power Networks (First-tier Tribunal), a cautionary tale on structuring to maximise consortium relief The podcast also covers HMRC’s new guidance on advance pricing agreements for cost contribution arrangements, the government’s recently published tax policy making principles, Revenue & Customs Brief 4 (2025) on input tax recovery in respect of investment and administration costs linked to occupational pension funds and what’s next for Pillar Two.

Tax News: The One Big Beautiful Bill 27.06.2025 29min

Zoe Andrews and Tanja Velling are joined by Arvind Ravichandran, Tax Partner at Cravath, to discuss the impact the proposed section 899 could have on US capital markets if enacted but how it is unlikely to be a big issue in practice. They cover: The purpose and potential withdrawal from the Bill of Section 899, a proposed tax on foreign investors, in response to global tax developments How changes to the GILTI regime aim to more closely align U.S. tax policy with OECD standards The mix of permanent tax cuts and temporary “America First” measures included in the Bill Key negotiation points for Congress including the SALT cap, Medicaid reforms, and clean energy tax credits

Tax News: June 2025 05.06.2025 26min

Zoe Andrews and Tanja Velling discuss the Upper Tribunal’s decisions in Walkers Snack Foods on the VAT classification of “Sensations Poppadoms” and Rettig Heating Group, the judicial review of HMRC’s refusal of a late claim to set off a non-trading loan relationship deficit. They then discuss the Court of Appeal’s decision in Beard on the meaning of “dividends of a capital nature”. The podcast also covers the UK government’s plans to modernise stamp taxes on shares, draft legislation for the reform of diverted profits tax, and transfer pricing and permanent establishment legislation, and a consultation on the potential changes to the process for resolving tax disputes. It further discusses HMRC’s revised unallowable purpose guidance and international news including on a US tax change (the addition of a new Code section 899) that could significantly increase the tax cost of investing in the US for residents of countries that are deemed to impose “unfair” taxes.

Tax News: May 2025 01.05.2025 24min

Zoe Andrews and Tanja Velling discuss the First-tier Tribunal’s decisions in: Candy giving overpayment relief for an SDLT charge on the substantial performance of a contract that was later cancelled Refinitiv on the taxpayer’s successful application for a direction to issue closure notices Vaccine Research Limited Partnership where purposive construction was used to look at transactions in the round and conclude that certain licence fees were not “income” They also cover the Court of Appeal’s decision in WTGIL on the scope of the VAT exemption for insurance intermediation. The podcast further discusses the postponement of the consultation on the tax treatment of pre-development costs, HMRC’s revised guidance on the salaried members rules, legislation on territories recognised as having implemented a qualifying income inclusion rule or domestic minimum tax, and a few other UK domestic and international developments.

Tax News: April 2025 03.04.2025 27min

Partner Alex Dustan from our Infrastructure and Energy team joined the April 2025 edition of our Tax News podcast to discuss the consultation on a “new permanent mechanism…to respond to future oil and gas price shocks” once the Energy Profits Levy ends, and the Court of Appeal’s decision in Gunfleet Sands on tax relief for pre-development costs. Zoe Andrews and Tanja Velling discuss the consultation on advance tax certainty for major projects and certain other points from the UK Chancellor’s Spring Statement. The podcast further covers the First-tier Tribunal’s decision in Hastings Insurance Services allowing input tax recovery in respect of a so-called “offshore looping structure” - the decision is of wider interest as an example of the application of the UK’s VAT rules post-Brexit - and the Court of Appeal’s decision in Innovative Bites on the VAT classification of Mega Marshmallows. Zoe and Tanja also touch on some EU developments.

Tax News: March 2025 06.03.2025 29min

In this podcast, tax associate Stephanie Mullins joins Zoe Andrews and Tanja Velling to discuss the UK Supreme Court’s decision in Royal Bank of Canada which could call into question received wisdom on the Ramsay principle of statutory interpretation. Zoe and Tanja draw out lessons on evidence and witness selection from the First-tier Tribunal’s decision in Lloyds Asset Leasing before touching on a High Court decision in a VAT-related judicial review, HMRC’s revised view on Condition C in the salaried members rules, updates on changes to inheritance tax reliefs and business rates, and a National Audit Office report on the administrative cost of the UK tax system. The podcast’s international section focuses on the US with updates on the domestic tax policy process, a new reciprocal trade and tariff policy, and a memorandum which foreshadows US action against digital services taxes and wider policies to regulate digital businesses.

Tax News: February 2025 06.02.2025 22min

In this podcast, Tax Associate Nadia Hourihan joins Zoe Andrews and Tanja Velling to discuss the Court of Appeal’s decision in ScottishPower that payments in lieu of penalties are tax deductible (even though no tax deduction would have been available for the penalties themselves). Zoe and Tanja further discuss the First-tier Tribunal’s decision in NHS Mid & South Essex that withholding tax applied to an interest element included in certain redress payments. The podcast also covers the potential impact of President Trump’s inauguration day announcement on international tax reform, before diving into recent UK developments in relation to the multinational top-up tax and the domestic top-up tax (new draft HMRC guidance and government amendments to the Finance Bill) and OECD publications on Pillar Two, including new Administrative Guidance.

Tax News: January 2025 09.01.2025 28min

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.

Tax News - U.S. tax policy post-election 10.12.2024 37min

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.

Tax News: November 2024 14.11.2024 28min

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.

Tax News: October 2024 10.10.2024 21min

In this podcast, tax associate Alex Sim joins Zoe Andrews and Tanja Velling to discuss the Upper Tribunal’s decision in Muller on the interaction of certain provisions in the intangible fixed assets regime with the rules on the taxation of partnerships. Zoe and Tanja also discuss the CJEU’s decisions in the Apple and UK CFC rules State aid cases, the Supreme Court’s decision in Professional Game Match Officials Limited on employment status and the stamp duty land tax case Brindleyplace in which the First-tier Tribunal employed purposive construction in favour of the taxpayer.

Tax News: September 2024 05.09.2024 22min

In this podcast, Zoe Andrews and Tanja Velling highlight points related to the Chancellor’s statement on public spending inheritance. They also discuss updated HMRC guidance on the multinational top-up tax and domestic top-up tax and comments from the business community. Before moving on to HMRC statistics on the tax take and litigation outcomes for 2023/24, Zoe and Tanja discuss VAT and the Clapham omnibus, two VAT-related developments in the EU and the Supreme Court’s decision in Centrica on the deductibility of M&A advisers’ fees as expenses of management.

How does the purpose of your borrowing impact tax deductibility? 28.08.2024 28min

Join Tanja Velling, co-host of our Tax News podcast and Tax Partners, Dominic Robertson and Charles Osborne, as they discuss the unallowable purpose rule, one of the UK's restrictions on companies deducting interest when calculating profits subject to corporation tax. This episode dives into: How this rule disallows interest deductions where a company’s borrowing is for a main tax avoidance purpose; and recent Court of Appeal decisions on what constitutes a main tax avoidance purpose and what this means for taxpayers, particularly in an M&A context.