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ARCHIVED: This Overview has been archived and is not maintained.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On 13 July 2017, when the government confirmed its intention to legislate the withdrawn provisions, it released amended legislation in relation to the corporate interest restriction, hybrid mismatches, the substantial shareholdings exemption, loss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

Upper Tribunal confirms HMRC’s power to issue assessments under TMA 1970 regarding pension scheme unauthorised payments (Trachtenberg v Revenue and Customs Commissioners)

Pensions analysis: Mr Trachtenburg (‘A’) appealed against the decision of the FTT, upholding HMRC’s assessments under section 29 of the Taxes Management Act 1970 (TMA 1970), charging him to income tax under sections 208 and 209 of the Finance Act 2004 (FA 2004). The sole issue was whether HMRC have power to issue assessments under TMA 1970, s 29. A contended: First, that the pension provisions in FA 2004 were comprehensive, the TMA 1970 does not enable HMRC to assess in the in the absence of any express application by FA 2004, s 255 or regulations issued under it, put beyond doubt by section 255(3)(b), which states that regulations under section 255 ‘may…provide for the application of any provision of the Tax Acts (with or without modification)’, unnecessary words otherwise; and Parliament had left it to HMRC to implement the necessary regulations, but they had failed to do so. Second, that TMA 1970, s 29 did not apply to income tax under FA 2004, ss 208 and 209, which did not charge income tax ‘for a year of assessment’. The Upper Tribunal (UT) rejected these arguments and dismissed the appeal. Written by Rebecca Murray, barrister at Devereux Chambers.

FTT dismisses taxpayer’s appeal against chargeable gains degrouping charge (Currys Retail Ltd v HMRC)

Tax analysis: In Currys Retail Ltd, the First-tier Tax Tribunal (FTT) dismissed the taxpayer’s appeal against a degrouping charge (under section 179 of the Taxation of Chargeable Gains Act 1992 (TCGA 1992)) in respect of the goodwill in four businesses that it had acquired intra–group. The FTT held that, on a realistic view of the facts, the taxpayer retained the businesses and goodwill at the time when it left the chargeable gains group and so was subject to the degrouping charge.

Tax weekly highlights—17 July 2025

This week's edition of Tax weekly highlights includes: (1) a reminder that Legislation Day will be on 21 July, (2) News Analysis of the Court of Appeal’s decision in Vietjet Aviation, and (3) News Analysis of the FTT’s decisions in Stenhouse and Abbey Healthcare (East Kilbride) Ltd.

Supreme Court holds that accommodation on support vessel was not incidental to oil drilling activities (HMRC v Dolphin Drilling Ltd)

Tax analysis: In Dolphin Drilling Ltd, the taxpayer chartered a vessel from an associated foreign company in order to provide support services to an oil driller in the North Sea. The vessel contained accommodation for the offshore oil workers. The taxpayer sought to deduct the hire costs of the vessel from its profits for corporation tax purposes, but HMRC maintained that there was a cap on deductions, pursuant to provisions in Part 8ZA of the Corporation Tax Act 2010 (CTA 2010). The issue was whether the accommodation on the vessel was incidental to other uses to which the vessel was likely to be put. The Supreme Court held that it was not as the accommodation served an independent purpose which meant that it was not incidental to, in the sense of arising out of, any other use. Written by Denis Edwards, barrister, Temple Tax Chambers.