2016–17—Autumn Statement to Finance Bill

ARCHIVED: This Overview has been archived and is not maintained.

This subtopic draws together content on the 2016-17 Budget and Finance Bill, starting with the Autumn Statement in November 2016, through the Budget in 2017 to the passage through parliament of the Finance (No.2) Act 2017. 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: Autumn Statement 2016 to Finance Bill 2017—Tax Analysis.

Finance (No 2) Act 2017

The government published the second Finance Bill of 2017 on 8 September 2017, containing most of the provisions that were dropped from the previous Bill, and accompanying explanatory notes. For more on this, see News Analysis: Publication of second Finance Bill 2017.

On 13 July 2017, when the government confirmed its intention to legislate the withdrawn provisions, it released amended legislation in relation to the corporate interest restriction, hybrid mismatches, the substantial shareholdings exemption, loss reliefs and disguised remuneration. For information on the key differences between the legislation

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Latest Tax News

Court of Appeal confirms that loans made under remuneration trust arrangements were taxable as disguised remuneration and related payments were not deductible (Marlborough DP Limited v HMRC)

Tax analysis: In Marlborough DP Ltd, the Court of Appeal dismissed the taxpayer’s appeal and upheld the decision of the Upper Tribunal (UT), confirming that loans made to a director under a remuneration trust (RT) scheme were taxable under the disguised remuneration legislation in Part 7A of the Income Tax Earnings and Pensions Act 2003 (ITEPA 2003) as being ‘in connection with’ employment. The court also agreed that the related payments were not deductible for corporation tax purposes, as they were not incurred wholly and exclusively for the purposes of the company’s trade.

UT holds that VAT exemption did not apply for single composite supply of financial services (JPMorgan Chase Bank NA v HMRC)

Tax analysis: In JPMorgan Chase Bank NA the Upper Tribunal (UT) dismissed the company’s appeal and upheld the First-Tier Tribunal (FTT) decision that the supply of intra-group services was a single composite taxable supply and the VAT exemption for financial services did not apply.

Supreme Court rules that the hire cap under the oil contractor regime applied to restrict deductions (HMRC v Dolphin Drilling Ltd)

Tax analysis: In Dolphin Drilling, the Supreme Court dismissed the company’s appeal, deciding that the ‘hire cap’ under the oil contractor regime applied to restrict the corporation tax deduction available to it for the cost of chartering a tender support vessel (TSV).

Tax weekly highlights—26 June 2025

This week's edition of Tax weekly highlights includes: (1) the Supreme Court’s decision in HMRC v Dolphin Drilling, (2) confirmation that the PISCES stamp tax exemption Regulations are to come into force on 3 July 2025 and (3) News Analyses on previously reported decisions Osmond and Allen v HMRC (on main purpose under ITA 2007, s 687), Smart v HMRC (on ‘receiving or entitled’ to income), Conservatory Insulations Northwest Ltd v HMRC (on VAT assessment time limits) and BGC Services Holdings LLP v HMRC (on the refusal of HMRC’s case management decisions permission to appeal application).