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Tax news in brief

Author: ICAEW

Published: 30 Apr 2024

Highlights from the broader tax news for the week ending 1 May 2024, including: an opportunity to give your thoughts on the non-dom changes; new legislation affecting building societies and individuals involved in the UEFA Champions League final; and changes to HMRC’s guidance for tour operators.

Government events to discuss non-dom changes

In the Spring Budget 2024, the government announced that the current remittance basis of taxation for UK resident non-domiciled individuals (non-doms) will be replaced by a new four-year foreign income and gains (FIG) regime from 6 April 2025. The government is holding a series of events between 13 and 31 May 2024 for stakeholders to provide comments on the proposed changes. Anyone wishing to attend an event should register their interest by 3 May.

HMRC questioned by MPs on helpline reversal

On 24 April 2024, the Treasury Committee heard evidence from Jim Harra and others as part of the committee’s ongoing scrutiny of HMRC’s work. A key topic for discussion was HMRC’s decision to reverse its plan to restrict access to its helplines.

Amendments made to the rules for transfers of business by building societies

The regulations providing for the tax consequences of transfers of business by building societies have been updated to reflect changes made in 2017 with regard to relief for losses. The changes, which had been consulted on, are outlined in a policy paper.

Exemption from tax for the UEFA Champions League final

Regulations have been made which provide for an exemption from income tax for qualifying income arising to individuals involved in the 2024 UEFA Champions League Final. The final is to be held in London on 1 June 2024.

Process for directors' loan accounts written off in insolvency procedures

In September 2022, HMRC initiated a new voluntary process for insolvency practitioners to help HMRC to manage the tax impacts of directors’ loan accounts (DLAs). Under the process, IPs were invited to send copies of their final reports in corporate insolvency cases to a new mailbox. This mailbox has now been decommissioned. Where IPs wish to engage with HMRC regarding DLAs they should write to the address set out in the guidance.

Changes to TOMS guidance on wholesale supplies

HMRC has published Revenue and Customs Brief 5 (2024), aimed at tour operators making business to business (B2B) supplies of wholesale services to other tour operators. Historically, HMRC’s position was that these supplies fell outside the scope of the tour operators’ margin scheme (TOMS). Tour operators could opt supplies of this nature into the TOMS. Following a recent tribunal case, HMRC has now concluded that B2B wholesale supplies are within the scope of the TOMS. By concession, tour operators may now opt B2B wholesale supplies out of the TOMS. HMRC considers that this has no practical impact but has updated its guidance to ensure it matches its policy on this subject.

The UK Internal Market Scheme (UKIMS)

HMRC has encouraged traders moving goods into Northern Ireland to consider joining the UKIMS. UKIMS allows trusted traders to declare eligible goods ‘not at risk’ with the result that they won’t pay EU duty for eligible goods moving from Great Britain to Northern Ireland. Improvements to processes are expected from 30 September 2024.

 

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