Introduction The Government’s overhaul of Agricultural Property Relief (APR) and Business Property Relief (BPR) has sent shockwaves through the farming community and family business sector. With the new restrictions taking effect for deaths after April 2026, landowners and business owners face an inheritance tax headache that their parents’ generation never encountered. But careful planning, particularly […]
Introduction The Upper Tribunal has provided critical guidance on a question that has long troubled tax practitioners: precisely when is a director’s loan “written off” for tax purposes? The decision in Quillan v HMRC [2026] UKUT 287 (TCC) offers important clarity… but also raises new questions about the boundary between commercial reality and tax consequences. […]
Introduction HMRC is conducting a war on two fronts. Recent analysis reveals the Revenue has simultaneously escalated its pursuit of overseas multinationals suspected of underpaying UK tax whilst launching an unprecedented campaign targeting domestic cryptocurrency investors. The combined strategy exposes HMRC’s dual priorities: extracting maximum yield from complex corporate structures while deploying technology-driven enforcement against […]
Introduction HMRC’s cryptocurrency enforcement capabilities have reached a new level of sophistication in 2026, with the department now routinely accessing exchange data through international information sharing agreements and deploying specialist blockchain analytics tools. For crypto holders who assumed their digital asset transactions were private, the reality check has arrived. The Information Flood The past twelve […]
Introduction Eighteen months after the most significant changes to the UK’s non-domicile regime in a generation, the first wave of disputes is beginning to reach the First-tier Tribunal. These cases offer early insights into how HMRC is interpreting the transitional provisions and where taxpayers may find themselves unexpectedly caught out. The April 2025 Overhaul The […]
