2021–22—Budget and Finance Bill

ARCHIVED This archived Overview draws together content on the fiscal events throughout the tax year 2021–22 starting with the publication of draft provisions for the Finance Bill 2022 (FB 2022) to the passage through parliament of the Finance Act 2022 (FA 2022). It is not maintained and is for background information only. For more information on the annual Budget and Finance Bill process, see Practice Note: The Budget and Finance Bill process.

All the analysis produced in this topic will be collected in Practice Note: 2021–22—Budget and Finance Bill—Private client analysis.

Finance Act 2022

FB 2022 (officially known as the Finance (No 2) Bill, because it

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Latest Private Client News

EU Council approves updated tax cooperation agreements with five countries

The Council of the European Union has approved updated tax cooperation and transparency agreements with Switzerland, Liechtenstein, Andorra, Monaco and San Marino. The updated agreements align with new international standards developed by the Organisation for Economic Co-operation and Development (OECD) and expand the automatic exchange of financial account information to include electronic money products and digital currencies. The new protocols also establish a framework for cooperation on value-added tax recovery and the prevention of tax fraud and evasion, while strengthening due diligence and reporting requirements to help tax administrations act more effectively on shared information. The updated agreements are set to enter into force on 1 January 2026, and the EU has indicated that it intends to further deepen cooperation on tax matters with Switzerland.

HMRC sends reminder letters on foreign tax credit relief compliance requirements

HM Revenue and Customs (HMRC) has issued reminder letters through its Wealthy team to individuals who claimed foreign tax credit relief in 2023/24. The letters are intended to ensure that recipients understand the criteria for the relief when making similar claims in 2024/25, particularly emphasising the requirement to verify provisions of relevant Double Tax Treaties. HMRC has advised letter recipients to review their 2023/24 tax returns and make any necessary amendments. The correspondence warns that penalties and interest may be charged if HMRC opens an enquiry and discovers errors. The reminder covers foreign tax credit relief for both employment income and non-employment income.

Private Client weekly highlights—20 November 2025

This week’s edition of Private Client highlights includes: (1) changes to fees for grant of representation applications; (2) the government’s announcement that a consultation on cohabitation and financial remedies is planned for Spring 2026; (3) A D Bly Groundworks and Civil Engineering Ltd v RCC, in which the Court of Appeal dismissed an appeal for tax deductions for an Unfunded Unapproved Retirement Benefit Schemes; (4) the final Charities Act 2022 provision which allows charities to make ex gratia or moral payments comes into force on 27 November 2025; (5) the Law Society joins professional services leaders in writing to the Chancellor to oppose LLP tax proposals; (6) Kieran Corrigan v OneE Group, where a company director was held personally liable for misuse of confidential information; (7) analysis of the FTT’s decision in Moir Management on penalties for DOTAS compliance failures, and (8) Font v Revenue and Customs Commissioners, in which the Administrative Court rejected an application for judicial review of the taxpayer’s treaty residence status.

Question of the week: H and W each own a half share of the family home. In his Will, H has created an interest in possession trust over his half share in favour of W with a right of occupation. Could the trustees force a sale of the house against W's wishes?

This Q&A considers whether, if H and W each own a half share of the family home and H’s Will creates an interest in possession trust over his half share in favour of W with a right of occupation, the trustees could force a sale of the property against W’s wishes.