Tax News: March 2024

In this podcast, Zoe Andrews and Tanja Velling share thoughts on the Spring Budget and the following recent cases: the Court of Appeal’s decision in Clipperton on a dividend replacement scheme, and the First-tier Tribunal’s decisions in Keighley, Stolkin and Mahmood, focussing respectively on the meaning of “control”, the question whether a company was trading following the appropriation to trading stock of land purchased as an investment, and whether a transaction was void because of a mistake as to its tax consequences.

The podcast also covers recent changes to HMRC’s guidance in respect of the salaried members rules and stamp taxes on shares as well as the call for evidence on the tax administration framework. Zoe and Tanja further touch on challenges to DAC6 and FATCA, the UN’s work on a framework convention on tax cooperation and other international tax news.