No Formal Proposals Following HMRC Consultation on Simplifying the Taxation of Offshore Interest

HM Revenue & Customs (HMRC) has published a summary of responses to its consultation on simplifying the taxation of offshore interest. However, the UK government has confirmed that it will not put forward any formal proposals at this stage. The consultation examined the practical difficulties caused by the mismatch between the UK tax year and […]

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Draft Finance Bill 2027 legislation: tax treatment of stablecoins

On 13 July 2026, HMRC published a policy paper and draft legislation setting out a new tax treatment for eligible stablecoins. The proposals, which are intended for inclusion in the Finance Bill 2027, seek to align the taxation of stablecoins more closely with that of money and to simplify the rules for individuals, trustees and […]

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Court of Appeal confirms English domicile despite move to Italy

The Court of Appeal has dismissed a husband’s appeal in Ferrara v Ferrara, confirming that the wife retained her domicile of choice in England and Wales despite having moved to Italy with the family in 2019. The issue was significant because the wife had issued divorce proceedings in England and relied on her English domicile […]

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UK Statutory Residence Test: FTT accepts transit and exceptional circumstances exceptions

The First-tier Tribunal has allowed a taxpayer’s appeal in a case concerning the UK Statutory Residence Test, providing useful guidance on the treatment of transit days and exceptional circumstances. In Parker v HMRC, the taxpayer was physically present in the UK at midnight on 100 days during the 2019/20 tax year. HMRC accepted that seven […]

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HMRC Discovery Assessment Out of Time: First-Tier Tribunal Rules in Taxpayer's Favour

Outram v HMRC [2026] UKFTT 248 (TC) The First-tier Tribunal (Tax Chamber) has allowed appeals brought by brothers Anthony and Ross Outram against discovery assessments issued by HMRC for the 2005–06 tax year, finding that neither brother had deliberately brought about a loss of tax. Background The case concerned a marketed tax avoidance scheme promoted […]

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