2024 Autumn Budget Predictions - Neil Fletcher (Video)

The Supreme Court has clarified how to determine whether LLP members have "significant influence" for tax purposes, establishing that qualifying influence must derive from legally enforceable rights traceable to the LLP agreement rather than informal power or strong performance. This landmark ruling provides a structured framework for assessing member status prospectively...

The UK Government has launched a consultation proposing significant changes to the withholding tax regime on interest payments to overseas lenders. The proposed reforms would shift from HMRC's current gatekeeping role to a self-assessment system where UK borrowers independently determine treaty relief eligibility, fundamentally altering compliance responsibilities and risk allocation in cross-border lending arrangements.

Recent changes to inheritance tax rules have narrowed the charity exemption, potentially affecting charitable gifts in Wills made for "general charitable purposes." Donor-advised funds offer a flexible, tax-efficient alternative that allows individuals to maintain philanthropic intent while adapting to evolving circumstances and involving future generations in charitable giving.

HMRC has proposed new legislation requiring taxpayers to correct known inaccuracies in tax returns, with failures to act being treated as deliberate behaviour attracting higher penalties and extended assessment periods. The draft legislation introduces a statutory duty to correct errors once identified and grants HMRC power to issue Customer Correction Notices, fundamentally shifting tax compliance from a technical exercise to a governance obligation that boards must actively oversee.

Understanding the complexities of inheritance tax on trusts can be challenging for practitioners navigating Scottish private client law. This practical guide demystifies the 10-year anniversary charge, providing essential insights into calculation methods, exemptions, and strategic planning considerations that trustees and advisors need to master.

The Government's draft legislation for a new Securities Transfer Tax (STT), published on 13 July 2026, was a bit of a landmark. Tax advisers will tell you, with a mix of shame and pride, that we still occasionally have to refer to nineteenth century legislation. The Stamp Act 1891 remains the foundation of stamp duty payable on share sales. The whole law in this area is a patchwork of bits of legislation spanning more than a century.

HMRC's enforcement agenda continues to intensify with new criminal offences for reckless statements, mandatory error correction obligations, and expanded compliance burdens on taxpayers and advisers. Recent Supreme Court decisions in BlueCrest and HFFX have narrowed the ground available to taxpayers, while the Court of Appeal's pushback in M R Currell offers some relief against overreach in disguised remuneration rules.

The First-tier Tribunal examined whether HMRC could retrospectively impose late payment penalties and surcharges after reallocating tax payments made by a taxpayer who had entered into unsuccessful tax avoidance schemes. The case centered on the critical question of whether tax liability should be assessed at a specific point in time or whether subsequent payment reallocations could create retroactive late payment scenarios.

The Scottish Government recently published its review of wealth taxation in Scotland. The report does not recommend introducing a wealth tax, but it does consider whether one could operate effectively within Scotland's fiscal and constitutional framework.

The Upper Tribunal’s recent decision in FC Shipping & FB Shipping v HMRC [2026] UKUT 305 (TCC) is a reminder that ship financiers cannot both eliminate most of the commercial risks of a leasing arrangement and retain tax benefits that are intended to reward risk-bearing investment.