Tax News

Tax News: July 2025

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Zoe Andrews and Tanja Velling discuss the following recent cases:

  • Dolphin Drilling: the Supreme Court’s decision on the meaning of “incidental” should not be read as having wider application beyond the oil contractor regime
  • Haworth (Court of Appeal) applying the place of effect management test to a trust in the context of a “round the world” capital gains tax scheme
  • Marlborough DP (Court of Appeal) on the tax treatment of a remuneration structure involving loans made by a trust and the meaning of “in connection with” in Part 7A of ITEPA
  • Osmond: the Upper Tribunal held that it was an error of law to equate seeking a capital gains tax relief with having a main purpose of obtaining an income tax advantage
  • Eastern Power Networks (First-tier Tribunal), a cautionary tale on structuring to maximise consortium relief

    • The podcast also covers HMRC’s new guidance on advance pricing agreements for cost contribution arrangements, the government’s recently published tax policy making principles, Revenue & Customs Brief 4 (2025) on input tax recovery in respect of investment and administration costs linked to occupational pension funds and what’s next for Pillar Two.

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    Tax NewsBy Slaughter and May