On the 26th of November, the Chancellor of the Exchequer, Rachel Reeves, unveiled the 2025 Autumn Budget, setting out a programme focused on stability, investment, and long-term economic growth. Below is a summary of the key announcements. Rachel Reeves’ Budget centred on rebuilding the UK economy while adhering to “iron-clad fiscal rules”, with an emphasis […]
IntroductionIn Boulting v Revenue and Customs Commissioners [2025] UKFTT 1272 (TC), the First-tier Tribunal considered whether proceeds from a company’s purchase of its own shares should be treated as an income distribution or as a capital disposal subject to capital gains tax. The decision provides helpful clarification on how the “benefit of the trade” test […]
In T Masters v HMRC [2025] UKFTT 967 (TC) (11 August), the First-tier Tribunal concluded that pension withdrawals taken from a self-invested personal pension (SIPP) by an individual living in Portugal were outside the scope of UK taxation. The Tribunal decided that the link to Mr Masters’ past employment remained intact despite the transfer of […]
The Court of Appeal has reaffirmed HMRC’s longstanding approach to the place of effective management (POEM) of trusts in the context of pre-2006 “round-the-world” tax avoidance schemes. In Haworth v HMRC [2025] EWCA Civ 845, the Court held that the POEM of a trust that had briefly appointed Mauritian trustees was, in substance, in the […]
In a decision with important implications for property investors and developers, the Court of Appeal has upheld HMRC’s interpretation of “residential property” for Stamp Duty Land Tax (SDLT) purposes, confirming that substantial renovation needs do not necessarily disqualify a property from being treated as residential. In Mudan v HMRC [2025] EWCA Civ 799, the taxpayers […]
