Pump Court Tax Chat

About Pump Court Tax Chat

Pump Court Tax Chat brings you expert analysis of key, topical tax issues from the barristers from Pump Court Tax Chambers. Whether you are a tax professional, a solicitor, accountant or interested in tax law you are in the right place. As the UK’s leading tax chambers, our team of barristers dives deep into the latest tax news, key cases and important legislative updates. From the impact of major tax changes to practical advice for navigating HMRC enquiries, insights to keep you informed and ahead of the curve. Join us every month for discussions with top tax barristers covering everything from corporate tax to personal wealth tax issues. We will keep you up to date with the latest developments and ideas. Presenter: Laura Poots Producer: Peter Shevlin A C60 Media production for Pump Court Tax Chambers https://www.pumptax.com/

Publisher

Pump Court Tax Chambers

Category

business · education · news

Language

en

Explicit

No

First episode

4 Nov 2024

Latest episode

13 Apr 2026

Latest episodes

14 episodes in the feed.

1. 

   13 Apr 2026

   S2 Ep5: Employment tax roundup

   David Yates KC (https://www.pumptax.com/barrister/david-yates-kc/) and Sadiya Choudhury KC (https://www.pumptax.com/barrister/sadiya-choudhury-kc/) take a look a some of the latest employment tax cases and recent changes to employment tax legislation. Umbrella companies 2:01 Mainpay: Mainpay was an umbrella company providing the services of various employees whose assignments were sourced by an employment agency. The employment point in the case was the nature of the "overarching contract" between Mainpay and the workers, and specifically whether this allowed Mainpay to reimburse travel and subsidence expenses without accounting for income tax and NIC. Consideration of the Readymix Concrete test. Could you argue a "single discontinuous working employment relationship"? Legislation has now made arguing for overarching contracts very difficult (s339A ITPA). Other aspects of this case are discussed in the most recent Tax Litigation Update podcast. 9:20 PPS Umbrella and VAT mini-umbrella fraud category: Elphysic being the lead case which is heading for the Supreme Court. However new legislation is coming in April 2026 which makes umbrella companies jointly and severally liable for NICs. The government is also reviewing the operation of umbrella companies more widely. SARS 10:39 Saunders: stock appreciation rights (SARS) under a long term incentive plan. NB this case is currently on appeal. When an employee is promised something (like a contractual right) - is it the contractual right which is their earnings or is it the payment made later under it? Does Abbott v Philbin still hold good? Do SARS have a value in their own right? Does the employee derive realistic immediate value? IR35 legislation 21:51 Bryan Robson Ltd: payments for acting as an ambassador for Manchester United. Was it an employment contract under the hypothetical employment test? Whether all or part of the consideration was attributable to the contract allowing exploitation of image rights and, if so, was this outside IR35? Case is on its way to the UT. 27:50 New offset mechanism in the tax legislation to allow payments to be offset against PAYE liabilities. Will this mean a decrease in IR35 cases? Payments in lieu of notice 28:53 Rawlinson: was the payment in lieu of notice (PILON) (the employee was disabled due to cancer surgery) subject to income tax as earnings? Guidance on operation of the exception of s401/406 ITPA. Absence of express language as to the purpose of a PILON not necessarily fatal but leads to tax uncertainty. Salary sacrifice schemes 35:43 Best Connection: the company set up a travel payment scheme (BSS) linked to a salary sacrifice scheme. 38:20 Salary sacrifice legislation under ITPA: the new rules mean that salary sacrifice schemes are now brought within the benefits legislation with some exceptions (eg electric cars, pensions, bicycles). However, contributions about £2k will be subject to NICs from April 2029. Whilst Best Connection predates all this legislation, it is still helpful on whether something is actually a salary sacrifice scheme. There is draft legislation - National Insurance Contributions Employer Pensions Contributions Bill - and further guidance promised. Agency workers legislation 41:14 Tyler Security: were the dog handling services providing "personal services"? The supervision, direction and control "SDC" test. Citations Legislation ss 338 and 339A Income Tax (Earnings & Pensions) Act 2003 (ITEPA) s16 ITEPA Chapter 5, part 7 ITEPA ss49 - 61 ITEPA (IR 35) Schedule 1AB ITEPA s62 ITEPA s406 ITEPA s65 ITEPA s69A and 69B ITEPA National Insurance Contributions (Employer Pensions Contributions Bill ss44 - 47 ITEPA Chapters 7 and 10 Part 2 ITEPA Cases Mainpay Ltd v HMRC [2025] EWCA Civ 1290 Exchequer Solutions Ltd v HMRC [2024] UKUT 25 (TCC) Ready Mixed Concrete (South East) Ltd v Minister of Pensions and National Insurance [1968] 2 QB 497 HMRC v Payroll & Pension Services (PPS Umbrella Company) Ltd [2024] EWCA Civ 995 Elphysic Ltd v HMRC [2025] UKUT 236 (TCC) Saunders v HMRC [2025] UKUT 374 (TCC) Abbott v Philbin [1961] AC 352 Bridges v Hewitt [1957] 1 WLR 674 (also known as Bridges v Bearsley) Bryan Robson Ltd v HMRC [2025] UKFTT 56 (TC) Basic Broadcasting Ltd v HMRC [2024] UKUT 165 (TCC) HMRC v S&L Barnes Ltd [2024] UKUT 262 (TCC) HMRC v Professional Games Match Officials Ltd [2024] UKSC 29 Atholl House Productions Ltd v HMRC [2022] EWCA Civ 501 Kickabout Productions Ltd v HMRC [2022] EWCA Civ 502. Rawlinson v HMRC [2026] UKFTT 45 (TC) HMRC v Tottenham Hotspur Ltd [2017] UKUT 453 (TCC) Hasted v Horner [1995] STC 766 The Best Connection Group Ltd v HMRC [2024] UKFTT 1103 (TC) Tyler Security Ltd v HMRC [2025] UKFTT 1250 (TC) Producer: Peter Shevlin A pod60 (https://pod60.com/) production for Pump Court Tax Chambers (https://www.pumptax.com/)

2. 

   23 Mar 2026

   S2 3p4: Tax Litigation Update

   Ben Elliott (https://www.pumptax.com/barrister/ben-elliott/), Quinlan Windle (https://www.pumptax.com/barrister/quinlan-windle/) and Sam Glover (https://www.pumptax.com/barrister/sam-glover/)look at recent developments in litigation focusing on procedural issues such as late appeals (Medpro), burden of proof (Sintra), the jurisdiction of the tribunal, disclosure and duty of candour, use of AI in writing judgments, assessments and penalties (eg Mainpay). 2:07 Court of Appeal judgment in Medpro (late appeals and in particular the Martland approach) – The UT can give guidance and the correct guidance in relation to late appeals is theMartland approach. Higher courts can only interfere with that guidance if there has been an error of law. Has the CA widened the grounds for appeal? Some practical points arising from the decision. 20:50 Sintra - Court of Appeal judgment concerning burden of proof in penalty cases. 25:33 Jurisdiction of tribunal to consider public law points – in particular the recent decision in Morrisons. How to protect the taxpayer's position with parallel judicial review proceedings and statutory appeals. 38:30 Use of AI in writing judgments – How are the courts using AI? 40:45 Disclosure and the duty of candour – Do HMRC have a duty of candour before the FTT? Is it the same duty as in judicial review cases? Is it only HMRC who have a duty of candour in FTT cases? 43:40 Assessments, penalties and causation - Discussion of recent cases and principles laid down in Mainpay, Delphi and Boston Consulting Group. Citations Cases Medpro Healthcare Ltd & Ruppai v HMRC [2026] EWCA Civ 14, [2026] STC 253 Martland v HMRC [2018] UKUT 178 (TCC) Mitchell v News Group Newspapers [2013] EWCA Civ 1537, [2014] 2 All ER 430 Denton v TH White Ltd [2014] EWCA Civ 906, [2015] 1 All ER 880 HMRC v McCarthy & Stone [2014] UKUT 196 (TCC), [2014] STC 973 BPP Holdings Ltd v HMRC [2017] UKSC 55, [2017] 4 All ER 756 Perinpanathan v City of Westminster Magistrates Court [2010] EWCA Civ 40, [2010] 1 WLR 1508 Competition & Market Authority v Flynn Pharma Ltd [2022] UKSC 14, [2023] 1 All ER 97 Price and others v HMRC [2015] UKUT 164 (TCC) Carbon Six Engineering Ltd v HMRC [2026] UKFTT 177 (TC) HMRC v Sintra Global [2025] EWCA Civ 1661 Henryk Zeman SP Zoo v HMRC [2021] UKUT 182 (TCC), [2021] STC 1706 Treasures of Brazil v HMRC [2024] UKFTT 929 Caredav Ltd v HMRC [2023] UKUT 179 (TCC) Chelsea Cloisters v HMRC [2025] UKFTT 205 (TC), [2025] SFTD 1105 Morrison Supermarkets v HMRC [2025] UKFTT 1542 (TC) R (on the application of Archer) v HMRC [2017] EWCA Civ 1962, [2018] STC 38 R (on the application of Weis) v HMRC [2025] EWHC 2479 (Admin), [2025] STC 1659 Cobalt Data Centre 2 LLP v HMRC [2019] UKUT 342 (TCC), [2020] STC 23 Evans v HMRC [2025] UKFTT 01112 (TC) Jordi Carulla Font v HMRC [2025] EWHC 3057 (Admin), [2025] STC 1935 Nottingham Forest Football Club v HMRC [2024] UKUT 145, [2024] STC 1105 Delphi Derivatives v HMRC [2026] UKUT 21 (TCC), [2026] STC 292 O'Neil & Ors v HMRC [2026] UKUT 13 (TCC), [2026] STC 199 Boston Consulting Group v HMRC [2026] UKUT 25 (TCC), [2026] STC 105 Lands Luo Limited v HMRC [2025] UKFTT 1207 (TC) Jeneruhl Trading Ltd & Another v HMRC [2024] UKFTT 735 (TC) Legislation CPR rule 3.9 Rule 28 procedure s29 Taxes Management Act s36 Taxes Management Act Producer: Peter Shevlin A pod60 (https://pod60.com/) production for Pump Court Tax Chambers (https://www.pumptax.com/)

3. 

   6 Mar 2026

   S2 Ep3: VAT: Classification or Characterisation of Complex Supplies

   Laura Poots KC (https://www.pumptax.com/barrister/laura-poots/) and Thomas Chacko (https://www.pumptax.com/barrister/thomas-chacko/) consider classification and characterisation in VAT cases. 2:00 What is meant by classification and characterisation: when you have identified you have a single supply or a set of multiple supplies, what is that supply? And is the position completely clear following Gray & Farrar? 2:50 The first step is identification of supply - to decide if you have a single or multiple supply - and then one looks at classification. Explanation of the two bases on which a single supply might be identified. 4:56 Is classification the final word on how the supply will be taxed? Case law and what are the tests? 7:26 Card Protection Plan (CPP) Supplies – principal-ancillary supplies and how they are classified. 8:12 Levob Supplies - In classifying these, different courts have looked at "overarching" or "economic reality" test and the "predominant element" test. 10:45 Gray & Farrar. Court of Appeal has now confirmed that there is a hierarchy of three tests (1) predominant element (2) principal-ancillary (3) overarching supply. 12:00 Predominance test: This is the primary test. Look at economic purpose and the typical customer (qualitative as well as quantitative). 13:55 Principal-ancillary test: a sense check on predominance, but also useful in working out the number of elements. 15:41 Overarching test: can assist in deciding predominance. 17:00 In applying these tests, how do you identify the elements of the supply? How does this all work in practice? 19:56 HMRC don't seem to view Gray & Farrar as settling the test in every case. What are HMRC's arguments and what are the problems with them? 21:05 HMRC argument 1: Individual elements cannot be singled out. 22:06 HMRC argument 2: subset of Levob supplies where no conceptual room for predominance test. HMRC's reliance on Blackrock and Deutsche Bank. 29:19 A practical example - Story Terrace. Court takes a lot of notice of contractual documentation and marketing descriptions. Potential relevance of online reviews. Demonstration of the importance of considering identification before classification. CITATIONS Blackrock Investment Management (UK) Ltd v HMRC [2020] STC 1445 Card Protection Plan Ltd v Customs and Excise Commissioners (Case C-349/96) [1999] STC 270 Finanzamt Frankfurt am Main V-Hochst v Deutsche Bank AG (C-44/11) [2012] STC 1951 HMRC v Gray & Farrar International LLP [2023] STC 327 Levob Verzekeringen BV and another v Staatssecretaris van Financien (C-41/04) [2006] STC 766 Město Žamberk v Finanční ředitelství v Hradci Králové (C-18/12) [2014] STC 1703 Spectrum Community Health CIC v HMRC [2024] STC 1124 Story Terrace v HMRC [2025] UKFTT 1554 (TC) Target Group Ltd v HMRC [2018] UKFTT 226 Talacre Beach Caravan Sales Ltd v Customs and Excise Commissioners (Case C-251/05) [2006] STC 1671 European Commission v France (Case C-94/09) [2012] STC 573 EC v Grand Duchy of Luxembourg (Case C-274/15) [2017] ECR Producer: Peter Shevlin A pod60 (https://pod60.com/) production for Pump Court Tax Chambers (https://www.pumptax.com/)

4. 

   18 Dec 2025

   S2 Ep2: Judicial review in tax cases procedure substance and practical impact

   David Ewart KC and Laura Ruxandu examine judicial review in tax cases, covering procedure, substance, and practical impacts, including extra-statutory rulings, published statements, and procedural errors; this is an interview.

5. 

   6 Oct 2025

   S2 Ep1: Environmental taxes: a look at landfill tax reform and the carbon border adjustment mechanism (CBAM)

   Industry experts discuss environmental taxes, examining landfill tax reform and the carbon border adjustment mechanism, offering insights into current legislation and future implications.

6. 

   9 Aug 2025

   S1 Ep8: Beneficial tax treatments available for expenditure on Research & Development

   Thomas Chacko and Quinlan Windle explore beneficial tax treatments for Research & Development expenditure, including scheme outlines, the meaning of R&D, and handling HMRC inquiries.

7. 

   11 Jun 2025

   S1 Ep7: The UK's post-Brexit customs and excise duty regime

   Rupert Baldry KC and Sadiya Choudhury KC examine the operation of the UK's customs and excise duty regime post-Brexit, covering legislative changes, the relationship between old and new regimes, and recent cases.

8. 

   22 Apr 2025

   S1 Ep6: Continued relevance of EU law after Brexit

   Jeremy Woolf (https://www.pumptax.com/barrister/jeremy-woolf/) and Barbara Belgrano (https://www.pumptax.com/barrister/barbara-belgrano/) look at how Brexit affects the UK tax position and consider some of the issues which will be ongoing, at least in the near future. (3:08) Where we are today: you have to consider which period your case falls within. There are three periods to consider: (1) 2018 up to IP Completion Day being 31st December 2020 (2) 1 January 2021 - 31st December 2023 (3) 1st January 2024 onwards. The first period: up to IP Completion Day on 31st December 2020 (4:42) The UK still a member of the EU but subject to the 2018 Act which purport to have retroactive effect. Article 89 of the Withdrawal Agreement (endorsed by HMRC v Perfect) make ECJ decisions relating to litigation commenced before Brexit or during the first period binding. ECJ decisions post Brexit only persuasive. See Lipton and The Umbrella Interchange. (7:04) Effect of section 2 2018 Act - saves EU-derived domestic law before IP Completion Day subject to Section 5 (supremacy) and Schedule 1 (Francovich damages). (8:56) Schedules 1 and 8 2018 Act - transitional provisions. To what extent, post Brexit, can you rely on general principles of EU law? Allianz Global v Barclays. (12:01) Section 3 of the 2018 Act (incorporation of direct EU legislation) which is subject to Section 5 and Schedule 1. (13:06) Section 4 of the 2018 Act (the saving of rights under section 2 ECA). Wide rule important in direct tax field (eg transfer of assets code). Effect in tax law of The Freedom of Establishment and Free Movement of Services EU Exit Regulations 2019. Effect of EU Directives and CG Fry & Son Ltd. Purposive interpretation dealt with in section 6. Harris v Environment Agency. The second period: 1st January 2021 - 31st December 2023 (19:49) Section 6 of the 2018 Act (extent to which UK courts bound by ECJ judgments). HMRC v Perfect, Lipton and The Umbrella Interchange cases. The third period: post 1st January 2024 (22:18) RULA now takes effect. It is not retrospective and only covers disputes that relate to the period post January 2024. (23:53) Section 2 of RULA repeals section 4 of the 2018 Act. Section 3 of RULA abolishes the supremacy of EU law. Will therefore be very difficult to rely on EU law in the direct tax arena (even in Transfer of Assets Code) post 1st January 2024. (25:54) VAT and excise duties in a different position due to section 28 Finance Act. (27:10) Section 6 of RULA is not yet in force. Amended test as regards looking at earlier cases. VAT most likely to be affected. EU law remains very relevant up to 1st January 2024, despite Brexit. And EU law remains relevant going forward in the VAT context. After 1st January 2024 EU law may still have an impact on the construction of UK law. Citations Legislation Retained EU Law Revocation & Reform Act 2023 ("RULA") European Union (Withdrawal) Act 2018 (the "2018 Act") Article 89 Withdrawal Agreement The European Communities Act 1972 The Freedom of Establishment and Free Movement of Services EU Exit Regulations 2019 Section 28 Finance Act 2024 Transfer of Assets Code Cases HMRC v Perfect [2022] EWCA Civ 330 Lipton v BA Cityflyer Ltd [2024] UKSC 24, 3 WLR...

9. 

   6 Feb 2025

   S1 Ep5: Beneficial entitlement after Hargreaves

   David Milne KC (https://www.pumptax.com/barrister/david-milne-kc/), Richard Vallat KC (https://www.pumptax.com/barrister/richard-vallat-kc/) and Calypso Blaj (https://www.pumptax.com/barrister/calypso-blaj/) discuss the implications of Hargreaves, in particular: What we can say about what is meant by "beneficial entitlement"? How is it different to "beneficial ownership"? And indeed to the trust law concept of both? Is there a different international fiscal meaning of beneficial entitlement? The panel look at where these issues may come up in practice. How definitive is the Hargreaves case? They also take a look at Altrad Services and the loss of beneficial ownership. Discussion of Hargreaves 2:38 Whether interest payments made to a UK resident company fell within an exception to the obligation to withhold tax on payments of interest under ITA. This depends on whether the recipient is beneficially entitled to the income. The CA reviewed the case law (para 49ff of the judgment). It then applied the principles to the facts (para 61ff). 8:10 It is important that the provisions put in place were specifically to obtain a tax advantage (which was admitted). The question was whether the tax planning worked. The recipient of the interest payments was under a contractual obligation to pay on the money it received so was it the beneficial owner therefore? The judgment gives guidance as to the domestic meaning of beneficial entitlement. 11:39 What of the rival definition of "beneficially entitled", also known as the international or fiscal meaning? Should this be adopted in a withholding tax situation? Discussion of Indofood and the ECJ cases in 2019. The international, fiscal meaning has to take into account the objects and purposes of the Convention including avoiding double taxation. This differs from the domestic law requirements per Ramsay of whether the concept fits within the statutory purpose and context of the provisions. 17:05 Conduit arrangements (insertion of a company) caught under either definition. However, theoretically there may be other cases where you are treated as being beneficially entitled under say the international, fiscal meaning but not under the domestic meaning. 18:35 The domestic meaning should not be dependent on finding a tax avoidance motive. Losing beneficial ownership 20:00 Altrad Services/Wiseman. Turned on "ceasing to own" in s61 Capital Allowance Act. Marketed tax avoidance scheme. Application of Ramsay purposive principle. See Tax Journal article on Altrad in July 2024. Case quite an extreme example so there might be other cases which are less clear cut. 28:07 NB there does not have to be someone who has beneficial ownership. Areas where beneficial ownership comes up 28:47 Withholding tax on interest payments, double tax treaties (dividends and royalties), domestic group relief provisions (eg CGT, substantial shareholding exemption, SDLT). Other comments 30:52 What if the conduit company in Hargreaves had actually used some/all of the money even for a short period? Or had another reason for existing other than being a conduit? 31:54 What if in Altrad, the complex arrangements designed to take advantage of capital allowances had actually been subject to a contract...

10. 

    15 Jan 2025

    S1 Ep4: Unallowable Purpose in the Loan Relationship Code

    In this episode, Elizabeth Wilson KC (https://www.pumptax.com/barrister/elizabeth-wilson-kc/) and Ronan Magee (https://www.pumptax.com/barrister/ronan-magee/) take a look at the "unallowable purpose rule" in the loan relationship code and in particular three recent Court of Appeal cases – Kwik-Fit (in which Elizabeth Wilson KC and Ronan Magee acted), BlackRock and JTI Acquisitions (in which Elizabeth Wilson KC acted). (2:28) outline of the unallowable purpose rule. It involves a multi-layered test. (4:45) a key element is what, as a matter of fact, is the group's purpose in organising the borrowing. You decide this by looking at all the facts therefore. Discussion of this in relation to the JTI Acquisitions case, Kwik-Fit and BlackRock. (9:48) companies have been trying to narrow what the courts can consider when applying the test. The Court of Appeal has clearly shown this cannot be done. (11:52) JTI Acquisitions underlines that a company must prove its case on all the facts. It cannot be selective. (13:50) Do you need to be coming to the UK for other reasons, not just tax reasons, in order to benefit from the rule? (16:00) Syngenta: there must be proper evidence and not window dressing/assertions. What role do documents and witness evidence have in establishing facts? Importance of getting all your evidence (documentary and witness) before the tribunal. (22:45) Kwik-Fit: genuine commercial losses in one part of the group which they sought to set against profits in other parts of the group. The disallowed losses were, however, capped which shows the attribution rule in its safeguarding role. (29:01) new loan relationship code anti-avoidance provision ss445B - D. (30:47) some questions are not yet answered (eg attribution). Cases/legislation Cases Kwik-Fit [2024] EWCA Civ 434 Blackrock [2024] EWCA Civ 330 JTI Acquisitions [2024] EWCA Civ 652 Fidex [2016] EWCA Civ 385 Travel Documents Service [2018] EWCA Civ 549 Syngenta [2024] UKFTT 998 (TC) Gestmin [2013] EWHC 3560 (Comm) Kogan v Martin [2019] EWCA Civ 1645 Euromoney [2022] UKUT 205 (TCC) Legislation ss441 and 442 Corporation Tax Act 2009 s1139 Corporation Tax Act 2010 ss445B - D Corporation Tax Act 2009

11. 

    19 Dec 2024

    S1 Ep3: Important changes for non-doms following the October 2024 Budget

    The October 2024 budget proposes a number of very significant changes for those who were previously considered “non-domiciled” for tax purposes, with effect from 6th April 2025. James Rivett KC (https://www.pumptax.com/barrister/james-rivett-kc/) and Emma Chamberlain (https://www.pumptax.com/barrister/emma-chamberlain-obe/) are private client tax specialists who act for both clients and HMRC. They take a balanced look at some of the fundamental features of the proposals highlighting some of the main features, explaining what the new rules will do, what they don’t do, how they will/may work, who is affected and what one should be thinking of doing now if you are or are advising someone previously treated as a “non dom”: (2.07) Rewrite of the relevance of domicile. (2.36) The background to the proposed changes and what we can expect in the months to come, including HRMC’s technical note of 30th October 2024. (6.37) The new regime for “qualifying new residents” – part of the abolition of the remittance basis. They identify some of the potential difficulties such as the fact you cannot claim later and also the matching rules are affected. (11.45) Transitional reliefs. (26.09) Why the remittance basis is still relevant. (30.22) Changes to Inheritance Tax for both individuals (30.22) and trusts (36.18). (41.40) Transitional provisions including discussion of the relevant property regime and new exit chanrges (45.40), funding the new charges (49.55) and double tax treaties (51). (54) Should you consider leaving the UK? (57.57) Should you consider coming to the UK? Addendum: If you are foreign domiciled and deemed domiciled but leave by April 2025 only a 3 year tail applies; if you are foreign domiciled and not deemed domiciled but have been here for more than 10 years no three year tail applies if you leave by April 2025. Useful links HMRC’s technical note of 30th October 2024:Reforming_the_taxation_of_non-UK_individuals.pdf (https://assets.publishing.service.gov.uk/media/672105124da1c0d41942a8a8/Reforming_the_taxation_of_non-UK_individuals.pdf) “Trust Taxation & Estate Planning (https://www.sweetandmaxwell.co.uk/Product/Private-Client/Trust-Taxation-and-Estate-Planning/Hardback/30804946)” – Chamberlain & Whitehouse (Sweet & Maxwell) 5th edition 2024 Legislation Acts referred to Inheritance Tax Act 1984 Taxation of Chargeable Gains Act 1992 Taxation (International & Other Provisions) Act 2010 Taxes Management Act 1970 Income Taxes Act 2007 Finance Bill – 7th November 2024 – schedule 9: Finance Bill publications - Parliamentary Bills - UK Parliament (https://bills.parliament.uk/bills/3873/publications) Particular clauses referred to Section 809L ITA 2007 Section 809P(12) ITA 2007 IHTA S49(1) taking precedence over s48(3) FA 1986 Section 102(4) Cases Sehgal v HMRC [2024] UKUT 00074 Addendum: If you are foreign domiciled and deemed domiciled but leave by April 2025 only a 3 year tail applies; if you are foreign domiciled and not deemed domiciled but have been here for more than 10 years no three year tail applies if you leave by April 2025

12. 

    9 Dec 2024

    S1 Ep2: Post Budget Thoughts

    Now the dust has settled following publication of the 30th October 2024 budget, Kevin Prosser KC (https://www.pumptax.com/barrister/kevin-prosser-kc/) and David Yates KC (https://www.pumptax.com/barrister/david-yates-kc/) give their thoughts on certain aspects of the budget, looking at important changes to CGT and IHT, and against the backdrop of the GAAR (general anti-abuse rule). Kevin and David's discussion covers: Capital Gains Tax (from 2.17 minutes) new anti-forestalling provisions unconditional contract planning and the use of overseas entities investors' relief in respect of gains on sale of shares in listed companies pilot trusts the consequences of the transfer of assets when limited liability partnerships become body corporates (s59A and s59AA TCGA) employee ownership trusts (ss236H - P of TCGA 1992) Inheritance Tax (from 25.21 minutes) employee benefit trusts Post 6 April 2026 tax planning (partnerships, reorganising share capital) now APR and BPR has been reduced actual domicile/domicile of choice The implications of the budget on "non doms" will be discussed by James Rivett KC (https://www.pumptax.com/barrister/james-rivett-kc/) and Emma Chamberlain (https://www.pumptax.com/barrister/emma-chamberlain-obe/) in a separate podcast. Cases and legislation referred to WT Ramsay Ltd v IRC [1982] 2 AC 300 Rysaffe v IRC [2003] EWCA Civ 356 Barker v Baxendale Walker [2017] EWCA Civ 2056 Finance Act 2020 Finance Bill 2024 Inheritance Tax Act 1984 (in particular ss 13, 28, 86) Taxation of Chargeable Gains Act 1992 (in particular ss17,18, 28, 59A, 59AA, 236H - P)

13. 

    20 Nov 2024

    S1 Ep1: Assessments: Recent Litigation Developments

    Keep up to date with all things tax law related with the Pump Tax Chat, brought to you by leading UK tax set, Pump Court Tax Chambers. In our latest episode, Laura Poots and Ben Elliott discuss the latest case law developments in HMRC’s powers of assessment, for both direct and indirect tax. They cover issues of carelessness, deliberate behaviour and protective assessments. All the legislation and cases mentioned in the podcast as well as a transcription of the episode can be found on the podcast page on our website here (https://www.pumptax.com/resources/). You can find out more about Pump Court Tax Chambers here (https://www.pumptax.com/) and on the speakers here: Laura Poots (https://www.pumptax.com/barrister/laura-poots/) / LinkedIn (https://www.linkedin.com/in/laura-poots-513ba533/) Ben Elliott (https://www.pumptax.com/barrister/ben-elliott/) / LinkedIn (https://www.linkedin.com/in/ben-elliott-86444193/)

14. 

    4 Nov 2024

    Pump Court Tax Chat: Trailer

    Welcome to Pump Court Tax Chat, the podcast brought to you by the expert barristers at Pump Court Tax Chambers. Whether you're a business owner, tax professional, or just interested in tax law, you're in the right place! As the UK's leading tax chambers, our team of barristers dives deep into the latest tax news, key cases, and important legislative updates. From the impact of major tax changes to practical advice for navigating HMRC enquiries, Pump Court Tax Chat delivers insights to keep you informed and ahead of the curve. Join us every month for discussions with top tax barristers, covering everything from corporate tax to personal wealth tax issues. We’ll help you keep up to date with the latest developments and ideas —one episode at a time. Subscribe now to Pump Court Tax Chat on all major podcast platforms, and stay tuned for our first episode, where we explore some of the recent cases affecting tax litigation in the UK.

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