Tax News Highlights: December 2021

In this podcast, Zoe Andrews and Tanja Velling cover three highlights from the UK’s Tax Administration and Maintenance Day – proposed reforms of the taxation of securitisation and insurance-linked securities, the Government’s response to the OTS review of CGT, indicating that an alignment of CGT and income tax rates is not currently on the cards, but the Government is considering whether to allow a corporate bond to include an irrevocable provision to specify that it is subject to CGT, and the action points from the review of large businesses’ experience of UK tax administration, including the development of new “Guidelines for Compliance”.

They further discuss the delayed publication of the consultation on a UK-wide online sales tax in the context of international tax reform as well as key takeaways from HMRC’s latest Report and Accounts and the Tax Receipts statistics for 2020 to 2021. The podcast also covers the Upper Tribunal’s decision in Assem Allam which casts doubt on HMRC’s guidance suggesting that, in the context of the definition of “trading company” in the TCGA, “substantial” could be taken to mean “more than 20%” and the First-tier-Tribunal’s decision in the Hargreaves Property Holdings on interest withholding tax.